United States Office of Solid Waste SW-966
Environmental Protection and Emergency Response July 1983
Agency Washington DC 20460
Solid Waste
&EPA Guidance Manual
for Hazardous Waste
Incinerator Permits
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GUIDANCE MANUAL FOR HAZARDOUS
WASTE INCINERATOR PERMITS
This publication (SW-966) was prepared
by the Office of Solid Waste and Mitre Corporation
under Contract No. 68-01-0092.
U S. Environmental Protection Agency
Region 5, Library (PI-12J)
77 West Jackson Boulevard, IZtft n«*
Chicago, It 60604-3590
U.S. Environmental Protection Agency
1983
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TABLE OF CONTENTS
LIST OF ILLUSTRATIONS ................................................ v
LIST OF TABLES [[[ vi
1.0 INTRODUCTION [[[ 1-1
1.1 Hazardous Waste Incinerator Permits ............................. 1-3
1.2 Content of the Permit Application ............................... 1-7
1.3 Permit Application Procedures ............................... .... 1-10
1.3.1 New Incinerators. ..................................... 1-10
1.3.1 Existing Incinerators ................................. 1-12
1.4 Use of this Manual .............................................. 1-14
2.0 EVALUATION OF THE PERMIT APPLICATION ............................ 2-1
2.1 Evaluating the Waste Analysis Information ....................... 2-2
2.1.1 Analysis for POHC Selection ........................... 2-3
2.1.2 Analysis for Other Waste Characteristics .............. 2-5
2.1.3 Analysis Required to Support Exemption ................ 2-6
2.2 Designating Principal Organic Hazardous Constituents ............ 2-15
2.3 Review of the Trial Burn Plan ................................... 2-30
2.4 Evaluating the Design of the Trial Burn ......................... 2-31
2.4.1 Selecting the Trial Burn Waste Feed ................... 2-35
2.4.2 Operating Conditions .................................. 2-41
2.4.3 Provisions for Stack Gas Sampling and Monitoring ...... 2-44
3.0 EVALUATION OF INCINERATOR PERFORMANCE DATA ...................... 3-1
3.1 Evaluation of Data Submitted in Lieu of Trial Burn Results ...... 3-1
3.1.1 Similarity of Wastes .................................. 3-2
3.1.2 Similarity of Incinerator Units ................... .... 3-3
3.2 Interpretation of Engineering Data .............................. 3-5
3.3 Calculation of Destruction and Removal Efficiency (ORE) ......... 3-5
3.4 Hydrogen Chloride Emissions ..................................... 3-12
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TABLE OF CONTENTS (Concluded)
4.0 SPECIFICATION OF PERMIT CONDITIONS .............................. 4-1
4.1 Specification of Operating Requirements from Performance
Data .............. . ............................................. 4-2
4.1.1 Carbon Monoxide Level in the Stack Gas ................ 4-4
4.1.2 Waste Feed Rate ....................................... 4-5
4.1.3 Combustion Temperature ............. , .................. 4-11
4.1.4 Combustion Gas Flow Rate., ............................ 4-12
4.1.5 The Emergency Waste Feed Cutoff System ................ 4-14
4.2 Limitations on Waste Feed Composition ........................... 4-16
4.2.1 Allowable Waste Feed Constituents ..................... 4-17
4.2.2 Limitations on Chemical and Physical Waste Feed
Characteristics ....................................... 4-20
4.3 Specification of Inspection Requirements for the Emergency
Waste Feed Cutoff System ................ . ....................... 4-24
5.0 EXAMPLES OF SPECIFICATION OF PERMIT CONDITIONS .................. 5-1
5.1 Discusion of Example 1 ........................ . ................. 5-2
5.1.1 Case Description ...................................... 5-2
5.1.2 Development of Permit Conditions ................. , ____ 5-2
5.2 Discussion of Example 2 ......................................... 5-7
5.2.1 Case Description ...................................... 5-7
5.2.2 Development of Permit Conditions ...................... 5-10
5.3 Discussion of Example 3 ......................................... 5-12
5.3.1 Case Description ...................................... 5-12
5.3.2 Development of Permit Conditions ...................... 5-12
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LIST OF ILLUSTRATIONS
Figure Number Page
2-1 Water Vapor Content of Saturated Flue Gas 2-14
2-2 Schematic Diagram Showing Trial Burn Monitoring
Locations for a Liquid Injection Incinerator 2-47
2-3 Schematic Diagram Showing Trial Burn Monitoring
Locations for a Rotary Kiln Incinerator , 2-48
4-1 Example of Multiple Waste Feeds to a Rotary
Kiln Incinerator 4-9
5-1 Samples of Continuously Recorded Temperatures 5-6
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LIST OF TABLES
Table Number Page
2-1 Rationale for Selection of Waste Analysis
Parameters 2-7
2-2 Acceptable Analytical Methods for Waste
Analysis.. 2-8
2-3 Heat of Combustion of Organic Hazardous
Constituents from Appendix VIII, Part 261 2-16
2-4 Ranking of Incinerability of Organic
Hazardous Constituents from Appendix VIII,
Part 261 on the Basis of Heat of Combustion 2-22
2-5 Checklist for Content of Trial Burn Plans. 2-32
2-6 Advantages and Disadvantages of Materials
to Increase Ash Content 2-39
3-1 Criteria for Determination of Incinerator
Simi larity « 3-4
3-2 Calculation of DRE 3-7
3-3 Sample Calculation of DRE 3-10
3-4 Calculation of Scrubber Efficiency 3-14
3-5 Sample Calculation of Scrubber Efficiency 3-15
3-6 Calculation of Particulate Emissions 3-17
3-7 Sample Calculation of Particulate Emissions 3-19
5-1 Sample Permit Application Data - Example 1 5-3
5-2 Sample Permit Conditions - Example 1 5-5
5-3 Sample Permit Application Data - Example 2 5-8
5-4 Sample Permit Conditions - Example 2 5-11
5-5 Sample Permit Application Data - Example 3 5-13
5-6 Sample Permit Conditions - Example 3 5-15
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GUIDANCE MANUAL FOR EVALUATING PERMIT APPLICATIONS
FOR HAZARDOUS WASTE INCINERATORS
1.0 INTRODUCTION
This manual provides guidance for review and evaluation of the permit
application information submitted to document compliance with the RCRA stand-
ards for incineration. Methods are suggested for designating facility-specific
operating conditions necessary to ensure compliance with the standards, on the
basis of the performance data supplied by the applicant. Each section of the
incineration regulation is addressed, including: waste analysis, designation of
principal organic hazardous constituents (POHCs) in the waste, and requirements
for operation, inspection and monitoring. Guidance is also provided for eval-
uating incinerator performance data and the procedures used in an incinerator
trial burn, during which performance data are generated.
The Solid Waste Disposal Act, as amended by the Resource Conservation and
Recovery Act of 1976 (RCRA) requires EPA to establish a national regulatory
program to ensure that hazardous wastes are managed in a manner that does not
endanger human health or the environment from the time the wastes are generated
until their eventual destruction or final disposition. The statute requires EPA
to:
"...promulgate regulations establishing such performance standards,
applicable to owners and operators of facilities for the treatment,
storage or disposal of hazardous waste identified or listed under
this subtitle, as may be necessary to protect human health or the
environment." (42 USC 6964)
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The incineration standards promulgated on January 23, 1981, and amended
on June 24, 1982, specify three major requirements regarding incinerator
performance. They are that the principal organic hazardous constituents
(POHCs) designated in each waste feed must be destroyed and/or removed to an
efficiency of 99.99%, that particulate emissions must not exceed 180
milligrams per dry standard cubic meter, corrected to 7% oxygen in the stack
gas, and that gaseous hydrogen chloride (HC1) emissions must be reduced
either to 1.8 kg per hour or at a removal efficiency of 99 percent. The
regulations also specify a number of requirements for waste analysis and
incinerator operation, monitoring and inspections. Finally, they establish
the procedures by which permits to hazardous waste incinerators will be
granted.
In addition to the standards for incineration, owners and operators of
hazardous waste incinerators must comply with the general facility standards
and administrative requirements for hazardous waste management facilities (40
CFR Part 264, Subparts A through H). These standards include requirements
for: security, facility inspections, personnel training, special
requirements for ignitable, reactive and incompatible wastes, facility
location with respect to floodplains and areas of seismic activity, special
equipment for emergency preparedness and prevention, a contingency plan and
procedures to be used in an emergency, use of the hazardous waste manifest
system, recordkeeping, reporting, and facility closure. They apply to all
regulated hazardous waste treatment, storage and disposal facilities and all
permit applications must ultimately include detailed descriptions of the
equipment, plans and procedures required by these standards. Guidance for
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review and evaluation of the permit application information documenting
compliance with the general facility standards and administrative
requirements is provided in other RCRA guidance manuals.
1.1 Hazardous Waste Incinerator Permits
Each facility treating, storing, or disposing of hazardous waste must
apply for and receive a permit which applies the regulatory standards to its
particular circumstances and states its particular compliance obligations.
RCRA allows existing facilities to operate during the period before a final
permit decision is reached, provided that the owner or operator has made a
timely submission of the required permit application. A facility is legally
eligible for operation during this period, called the period of "interim
status", only if it was in existence on November 19, 1980 and if the owner or
operator submits a RCRA permit application.
Because of the large number of RCRA permits that must be issued, the
permit application needed to qualify for interim status may be due years
before the facility's individual permit will be considered. Requiring all of
the information needed for a decision concerning the facility permit at the
time of qualification for interim status would result in a requirement that
owners and operators provide a great deal of information to the Agency long
before it is needed for regulatory purposes. Furthermore, because of the
lengthy period which ensues following qualification for interim status,
information provided so far in advance might well be outdated by the time EPA
begins to evaluate the permit application.
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To avoid this result, EPA has divided the permit application into two
parts. Part A, which is relatively brief, is filed by owners and operators
of existing facilities in order to qualify for interim status. Part B of the
permit application contains the balance of the information necessary to fully
evaluate the facility's performance and reach a decision concerning issuance
of a permit. EPA's standards for hazardous waste incinerators (40 CFR
264.340-264.351 and 40 CFR 270.ly and 270.62) specifically identify the
information necessary to complete the Part B application for a hazardous
waste incinerator.
Compliance with the standards for incineration of hazardous waste (40
CFR 264.340 through 264.351) may be initially established through performance
of a trial burn. During the trial burn, tne applicant tests the
incinerator's ability to destroy the hazardous waste, or wastes to be treated
at the facility, in compliance with the performance standards. Generally,
the applicant's goal in conducting the trial burn should be to identify the
most efficient conditions, or range of conditions, under which the
incinerator can be operated in compliance with the performance standards.
Often, this will require that the applicant test a range of operating
conditions during the trial burn in order to identify the best conditions.
In order to establish compliance with the performarce standard for
99.99% destruction and removal of organic waste constituents, the regulations
provide for selection, by the permitting official (the "permit writer"), of
principal organic hazardous constituents (POHCs) for each waste feed to be
burned. POHCs are hazardous organic substances present in the waste feed
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which are representative of those constituents most difficult to burn and
most abundant in the waste. The incinerator standards set out the criteria
to be used in selecting POHCs (i.e., difficulty of incinerability and
concentration). The destruction and removal efficiency is actually measured
only for the designated POHCs. The incinerator's performance in treating
POHCs is considered indicative of overall performance in treating other
wastes. This provision simplifies the sampling and anlysis efforts which are
necessary to determine whether the performance standard has been achieved,
thereby reducing the cost and complexity of the trial burn.
Compliance with the performance standard for control of gaseous hydrogen
chloride (HC1) emission is documented, during the trial burn, by measuring
HC1 in the stack gas. Similarly, compliance with the performance standard
for control of particulate emissions is documented by measuring the
particulate load in the stack gas during the trial burn.
Part B of the permit application for a hazardous waste incinerator may
include a detailed plan describing the test procedures, sampling and
analytical protocols and schedules for conducting a trial burn. This plan
should be reviewed by the permit writer and approved if found sufficient to
provide all necessary performance data. The trial burn plan is a required
component of a permit application for a new incinerator. Owners and
A "new" incinerator is one that was not in existence on November 19, 1980
and therefore does not qualify for interim status. The RCRA regulations
stipulate that owners or operators of new incinerators must apply for and
receive a RCRA permit before beginning construction.
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operators of incinerators currently in interim status are not obligated to
draw up a detailed trial burn plan for Agency approval prior to conducting
the burn. Performance data may be collected in the course of routine
operation during interim status. However, prior approval of a trial burn
plan will provide the applicant with assurance that the information collected
will be sufficient for preparation of the permit and that further data
collection efforts are not likely to be necessary. Furthermore, careful
planning of the trial burn will allow the applicant and Regional or State
representative to design a permit that is well tailored to the specific needs
of the facility and provides the greatest possible flexibility.
The performance data collected during the trial burn are reviewed and
evaluated by the permit writer and become the basis for settling the
conditions of the facility permit. Generally, the operating conditions, or
range of conditions, shown to result in acceptable incinerator performance
(as defined by the performance standards) will be designated in the permit as
allowable. The incinerator regulation requires that the permit specify:
• allowable waste analysis procedures;
0 allowable waste feed compositions (including acceptable variations
in the physical or chemical properties of the waste feed);
• acceptable operating limits for carbon monoxide (CO) in the stack
exhaust gas;
• waste feed rate;
• combustion temperature;
t combustion gas flow rate; and
• allowable variations in incinerator design and operating procedures
(including a requirement for cutoff of the waste feed during start-
up, shut-down and at any time when the conditions of the permit are
violated).
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The permit must also specify actions necessary to control fugitive emissions
from the incinerator, methods for continuous monitoring of operating para-
meters, and requirements for periodic inspection of the facility. Addition-
ally, the incinerator regulation allows the permit writer to specify any
other operating conditions necessary to assure that the performance standards
are being met.
In reviewing and evaluating the permit application, it is essential that
the permit writer make all decisions in a well-defined and well-documented
manner. Once an initial decision is made to issue or deny a permit, the
Subtitle C regulations (40 CFR 124.6, 124.7, and 124.8) require that either a
statement of basis or a fact sheet be prepared which discusses the reasons
for the decision. The statement of basis or the fact sheet then becomes part
of the administrative record (40 CFR 124.9), which is to be made available
for public review and comment as part of the permit review process (40 CFR
124.6 through 124.20).
1.2 Content of the Permit Application
The RCRA regulations allow incinerator owners and operators to select
one of several options for completing a permit application. First,
applicants seeking permits to burn wastes which are hazardous solely due to
their ignitable, corrosive or reactive properties are eligible for exemption
from most of the technical standards for incineration. These applicants are
required to submit only the information required by the general and
administrative standards, and a detailed waste analysis. Second, applicants
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not eligible for the exemption will be required to conduct a trial burn and
submit the results of all stack sampling and analysis with the permit
application. Third, as an alternative to conducting a trial burn, applicants
may submit waste analysis data and data describing the performance of a
similar incinerator burning a similar waste. This information will be
evaluated to determine whether it can be used to predict the performance of
the applicant's incinerator.
The information which must be submitted to show compliance with the
standards for incineration consists of five components: waste analysis
information, the facility description, the trial burn plan, performance data,
and proposed operating conditions. Waste analysis information includes all
sampling and analytical methods and plans for conducting both a detailed
waste analysis and periodic waste analysis to verify that the waste feed
composition entering the incinerator does not violate the conditions of the
permit. The results of a detailed waste analysis should also be provided.
This information will allow the permit writer to designate the principal
organic hazardous constituents of the waste.
The facility description includes, at a minimum, the linear dimensions
of the incinerator, capacity of the prime mover, description of the nozzle
and burner design and the location and description of temperature, pressure
and flow indicators and control devices. The applicant must also provide a
description of the auxiliary fuel system, the automatic waste feed cutoff
system, the air pollution control system and the stack gas monitoring system.
The trial burn plan should include a description of all sampling and
monitoring procedures and equipment, a test schedule and protocol, a descrip-
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tion of the range of operating conditions under which the incinerator will be
operated, and a description of emergency procedures for waste feed cutoff,
shutdown of the incinerator and control of emissions. The trial burn plan
should discuss all methods planned for testing the components of the
incinerator (e.g., waste feed mechanisms, monitoring devices, air pollution
control devices). In addition, the waste feed(s) to be used during the trial
burn snould be descriued in detail. This is particularly important in cases
where the applicant chooses to use a contrived blend of wastes or chemicals
instead of the waste that will normally be treated at the facility. For more
details on a contrived blend of wastes, refer to the discussion on artificial
waste in Section 2.4.1 of this manual.
If performance data is included, the permit application will primarily
consist of data collected during the trial burn. The applicant may
supplement the trial burn data with data or information collected previous to
the trial burn or with data generated by a similar incinerator. In some
cases, the applicant may have extensive data from a trial burn conducted at a
similar or identical incinerator burning a similar waste. This information,
if sufficient to write the permit conditions, may be used in lieu of a trial
burn (40 CFR 270.19(cjj. At a minimum, the performance data snould include:
o results of the waste analysis;
o results of the analyses of the scrubber solution, ash and other
residues;
o computations of the destruction and removal efficiency;
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o particulate emissions and HC1 emissions;
o identification of any fugitive emissions;
o average, maximum and minimum temperatures and combustion gas flow
rates; and
o results of any continuous monitoring.
Finally, the permit application should include a description of the con-
ditions under which the applicant proposes to operate the incinerator. Each
of the operating parameters identified in the regulations (40 CFR 264.345)
should be addressed. This portion of the permit application will vary in
detail and complexity, depending on the degree of flexibility desired in the
permit conditions.
1.3 Permit Application Procedures
1.3.1 New Incinerators. Prior to construction of the incinerator,
owners and operators of the new units who will conduct a trial burn are
required to submit a trial burn plan with the permit application. The
application will be processed through all of the required administrative
procedures (40 CFR Part 124), including preparation of a draft permit and
opportunity for public comment and hearing. After completion of this
process, a permit that establishes all of the conditions needed to comply
with all applicable standards will be .issued. This permit will be the
"finally effective RCRA permit" required (40 CFR 270(f)) for construction of
the incinerator.
The permit will be structured to provide for four phases of the
operation. Operating conditions will be specified for each phase. The
initial phase begins immediately following completion of construction.
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During this phase, the unit may be operated for "shake-down" purposes, in
order to identify possible mechanical difficulties, and to ensure that the
unit has reached operational readiness and has achieved steady-state
operating conditions prior to conducting the trial burn. This phase of the
permit is limited in duration to 720 hours of operation using hazardous waste
feed (one additional period of up to 720 hours may be allowed for cause).
Note that this does not limit burning of nonhazardous wastes or fuel.
After timely and satisfactory completion of all shake-down operations,
the second phase of the permit begins. This phase consists solely of the
period alotted for conducting the trial burn. Following completion of the
trial burn, a period of several weeks to several months will be necessary for
completion and submission of the trial burn results and subsequent
specification of operating conditions to reflect the results. During this
period, which represents the third operational phase of the permit, the
facility may continue to operate under specified operating conditions.
Detailed review of the trial burn results will show either that the
incinerator is capable of complying with the performance standards when
operating within the trial burn conditions, or that compliance was not
attained during the trial burn and a second test is necessary. If compliance
was shown, the permit may be modified to set, as the final operating
requirements, those conditions demonstrated during the trial burn. (See 40
CFR 122.17, "Minor Modifications of Permits"). If compliance has not been
shown and an additional trial burn is necessary, the permit must be modified
to allow for an additional trial burn. When all permit modifications are
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complete, the facility begins its fourth and final operating phase which
continues throughout the duration of the permit.
Permit modifications may be major or minor modifications. Minor
modifications are changes in the waste feed composition, operating
conditions, or other permit stipulations that are within the range of
allowable variations specified in a permit. Examples of minor variations are
an increase in the heating value of a waste and an increase in combustion
zone temperature. Minor permit modifications do not require review at a
public hearing. Major permit modifications are changes that are outside the
range of permitted values and equipment modifications that may affect
incinerator performance. Examples of major modifications are a decrease in
the heating value of a waste below the permitted value, a change in the
monitoring location of combustion zone temperature, and replacement of a
combustion chamber having different dimensions. Major modifications require
review at a public hearing.
1.3.2 Existing Incinerators. The application procedure for existing
facilities differs from new facilities because an existing facility in
interim status is authorized to burn hazardous wastes. Therefore, an
existing facility needs no prior approval to continue operation or conduct a
trial burn. However, without the permit writer's approval, the owner or
operator cannot be certain that the trial burn data will be sufficient to
meet the permit writer's needs. Thus, the applicant will find it
advantageous to obtain approval of a trial burn plan prior to conducting the
test. During review of the trial burn plan, the permit writer will designate
principal organic hazardous constituents (POHCs) to be monitored and will
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specify other requirements. However, the applicant may choose to collect
data during the course of normal operation under interim status or may
acquire data from similar facilities burning similar wastes to be submitted
with Part 8 of the permit application in lieu of conducting a trial burn
according to an approved trial burn plan.
Because RCRA provides for existing incinerators to operate under interim
status while awaiting the Agency's decision concerning permit issuance, these
facilities do not experience the operating restrictions which complicate the
permitting process for new incinerators. Owners and operators of existing
incinerators who will conduct a trial burn may suomit a trial burn plan
either before or with Part B of the permit application. The permit writer
will evaluate the plan and approve it after making all necessary
determinations (40 CFR 270.62)
If a trial burn plan is submitted and approved before the permit appli-
cation has been submitted, the applicant snould conduct the trial burn, and
submit the resulting data with the permit application. If completion of this
process conflicts with the date set for submission of the Part B application,
the applicant should contact the permit writer to extend the date for
submission of the Part B application, or submit the Part B without the trial
burn results and provide the data within 90 days following completion of the
trial burn. If a trial burn plan is submitted witn Part B of the permit
application, the permit writer, when approving the plan, will specify a time
period for conducting the trial burn and submitting the results. Following
submission of the trial burn results and the Part B application, the permit
writer will prepare a draft permit specifying the proper operating
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requirements, based on the results of the trial burn, along with all other
applicable permit conditions. This permit will then be processed through the
standard administrative procedures (40 CFR Part 124).
1.4 Use of this Manual
The information and guidance presented in this manual constitute sugges-
tions for review and evaluation, often based upon best engineering judgment.
The guidance is intended to help resolve technical issues on a case by case
basis, not to provide rigid rules to be applied in all circumstances. The
responsibility for applying the regulations and specifying the permit condi-
tions lies with the permit writer. This manual will assist the permit writer
in arriving at decisions in a logical, well-defined, and well-documented
manner. Checklists are provided throughout the manual to ensure that
necessary factors are considered in the decision process. Several options
for developing specific permit requirements are presented. The permit writer
is not limited to adopting only one option and is encouraged to tailor
permits to each applicant's situation. Technical data and numerical methods
are presented to assist the permit writer in evaluating an incinerator.
References are cited throughout this manual to aid the permit writer in those
instances where further guidance is necessary.
In addition to this guidance manual, permit writers use the "Engineering
Handbook for Hazardous Waste Incineration," EPA SW-889, IERL, Cincinnati,
Ohio.^ The Engineering Handbook provides background information to
familiarize the permit writer with current incineration technology. Permit
writers may also use the Hazardous Waste Incineration Data Base. This data
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base provides computer and hard copy access to trial burn data, permit
application data and information from incinerator manufacturers. The data
base is accessible at EPA regional offices and at EPA headquarters.
The permit writer may also require technical assistance in the
evaluation of certain permit applications, especially those for which there
are no precedents. To this end, the Agency has formed a Permit Assistance
Team (PAT). The team consists of experts in the field of hazardous waste
incineration. It has two primary functions: (1) to provide the Regional
Offices with direct access to specialized expertise related to hazardous
waste incineration, and (2) to provide EPA with increased capability to
respond quickly when applications are received. The members of the PAT
augment EPA staff capabilities concerning incineration hardware, facility
design, analytical measurements and protocols, site survey and evaluation,
and environmental impact modeling and assessment.
The permit writer should begin evaluating the application with exam-
ination of the trial burn plan. The elements and considerations that should
be included in the trial burn plan are identified and discussed in Chapter 2.
Guidance for evaluating the waste analysis plan and waste analysis data is
also presented in Chapter 2. This evaluation includes designation of the
principal organic hazardous constituents (POHCs) for each waste described in
a permit application. Guidance is presented in Section 2.1 for making this
designation.
Methods for evaluating incinerator performance data are presented in
Chapter 3. Sample calculations of destruction and removal efficiency (ORE),
scrubber efficiency, and correction of particular emissions are provided in
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Chapter 3. Guidance for the specification of operating requirements is
presented in Chapter 4 and examples of the development of specific permit
conditions from incinerator performance data are included in Chapter 5.
Incinerator design information may be evaluated using the methods pre-
sented in the Engineering Handbook. The purpose of this evaluation is to
ensure that the information is consistent with current engineering practice
and that the unit may be expected to achieve compliance with the performance
standards.
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2.0 EVALUATION OF THE PERMIT APPLICATION
Evaluating the permit application encompasses four major activities:
t Evaluating the waste analysis procedures and information;
• Designating principal organic hazardous constituents (POHCs) for the
waste feed;
• Reviewing and approving the trial burn plan and the proposed
operating conditions;! and
t Evaluating the incinerator design.
This chapter provides guidance for evaluating the waste analysis plan and data,
designating POHCs and evaluating the trial burn plan. Guidance for evaluating
incinerator design is provided in the Engineering Handbook.
The guidance presented in this chapter will assist the permit writer in
reviewing waste analysis data and the trial burn plan. This chapter
discusses the chemical and physical analysis of wastes, stack gases and other
incineration residues, use of contrived waste blends in the trial burn, and
alternatives for planning the trial burn. Section 2.2 presents a method for
selection of principal organic hazardous constituents (POHCs) from waste
analysis data. The permit writer should recognize that this method has been
selected as the best of several alternatives, after careful consideration of
the advantages and disadvantages of each. The POHC selection method
presented here may be used in
most cases, although there may be instances where the permit writer will
select some additional POHCs using other methods.
1 Operating conditions will often, but not always, be included in a trial
burn plan. Review and approval of a trial burn plan prior to conducting
the trial burn is required for new incinerators. For incinerators
operating in interim status,it is strongly recommended, but not
required, that a trial burn plan be submitted.
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2.1 Evaluating The Waste Analysis Information
Waste analysis for the RCRA program is conducted at two levels of detail.
A thorough waste analysis is required for initial characterization, providing
sufficient data for the permit writer to evaluate Part B permit applications,
trial burn plans, and permit modifications. Information regarding routine
variations in waste composition should be included in the initial
characterization. This information is used to establish permit conditions.
During on-going operational periods the applicant may analyze wastes less
extensively in order to ensure compliance with the permit conditions and to
detect manifest discrepancies during routine incincerator operation. The
analytical parameters for routine analysis are suggested by the applicant,
evaluated by the permit writer, and included in the waste analysis plan,
which is a part of the permit.
The permit application should identify the procedures used for sampling
and analyzing the waste feed?, the incinerator stack gas, and incineration
residues (e.g., bottom ash, scrubber solutions, and other residues from air
pollution control devices). Sampling and analysis methods that are not
standard EPA procedures should be described in detail. All sample
preparation and storage techniques should be described. Detection limits and
standard calibrations should be provided for each analytical method used.
The Agency has recommended sampling techniques and analytical methods
for waste analysis in its document Test Methods for Evaluating Solid Waste:
Physical/Chemical Methods (SW-846, Second Edition, July 1982). Methods for
2 The term "waste feed" is ,
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sampling and analysis of stack gases and other incineration residues are provided in
the EPA document , Sampling and Analysis Methods for Hazardous Waste Combustion
(Arthur D. Little, Inc., February 1983). The methods proposed in the trial burn
plan should be taken from those described in these two documents. The incineration
manual, however, provides only general methods for sampling and analysis, and
modifications to these methods should be made, if necessary, to ensure that 99.99%
destruction and removal efficiency can be verified. Such modificatons would
include, for example, increased sample collection times or modifications to the
elements of the sampling train.
Some applicants may propose the use of analytical methods different from
those recommended by EPA. In all such cases, detailed descriptions of the
analytical protocols should be provided. The permit writer must evaluate the
proposed analytical methods in order to determine whether they are equivalent to
those recommended by EPA. This evaluation should include consideration of factors
such as detection limits, precision, accuracy, and potential interferences.
2.1.1 Analysis for POHC Selection
In order to establish compliance with te performance standards for 99.99%
destruction and removal of organic waste constituents, the regulations provide for
selection, by the permit writer, of principal organic hazardous constituents (POHCs)
for each waste feed to be burned. POHCs are hazardous organic constituents of the
waste, selected from the list of hazardous constituents in 40 CFR Part 261, Appendix
VIII, that are representative of those constituents most difficult to burn and most
abundant in the waste. During the trial burn, the destruction and removal
efficiency is actually measured only for the POHCs and the incinerator's performance
in treating these substances is used to indicate overall performance in combusting
organic waste. This aspect of the incinerator standards simplifies the sampling and
analysis efforts which are necessary to determine whether the performance standard
has been achieved, thereby reducing the cost and complexity of the trial burn.
2-3
-------
To facilitate selection of POHCs and measurement of ORE, the applicant must
provide the permit writer with detailed waste analysis information. The
sampling and analysis manual describes a 3-step procedure for generating
the necessary analytical information in an efficient manner without requiring
rigorous quantitative analysis for hundreds of organic compounds. This
procedure, which employs a reverse search technique, reduces the complexity and
cost of waste feed analysis because the analysis is directed at those specific
compounds that are expected to be present in the waste.
In the first step of the procedure, the applicant should establish a list
of hazardous constituents, from among those listed in 40 CFR Part 261, Appendix
VIII, that are reasonably expected to be present in the waste feed. These
selections should be based on the applicant's knowledge of the waste normally
fed to the incinerator and the industrial processes from which the wastes are
generated.3 Once the list of "expected" hazardous constituents is completed,
the applicant should generate a chromatogram from a sample of the waste feed
using the mass spectrometer techniques presented in SW-846.
In the second step of the procedure, the applicant should conduct a
computerized reverse search of the chromatogram to identify and quantify any
of the "expected" constituents detected in the chromatogram. At this stage,
quantification of each constituent will not be highly accurate. The
concentation generated, however, will generally be sufficient for selection
of POHCs by the permit writer, and should be included in the trial burn plan.
Procedures for conducting the reverse search are provided in SW-846.
The trial burn plan must also identify any constituents from Appendix
VIII that are excluded from the analysis and provide the rationale for
the exclusions.
2-4
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The third step in the data collection process takes place at the time of
the trial step in the data collection process takes place at the time of the
trial burn and should be addressed in the trial burn plan. It is during this
step that the data needed to accurately calculate the incinerator's destruction
and removal efficiency are generated. Using the methods provided in SW-846, the
applicant should analyze the waste feed and the stack gas in order to quantify
POHC levels present in each, to the prescribed detection limits.
In order to maintain accuracy in the ORE calculation, waste feed should be
sampled periodically during the trial burn. In general, waste feed samples
should be collected simultaneously with stack gas samples. For example, the
trial burn plan may specify taking a 3-hour stack sample for each set of
operating conditions to be tested. During the 3-hour stack sampling period, the
waste feed could be sampled at 15-minute intervals and the samples composited
over the 3-hour period. In this manner, accuracy is maintained without
requiring analysis of very large numbers of waste feed samples.
2.1.2 Analysis For Other Waste Characteristics
In addition to identification and quantification of hazardous
constituents, the incinerator standards require the applicant to measure the
viscosity (where appropriate) and heating value of the waste feed. Viscosity
measurements provide the permit writer with information necessary to judge the
adequacy of liquid waste delivery systems. The heating value of the waste feed
is needed to determine and maintain adequate operating conditions and may be
used to establish permit conditions.
The standards also allow the Regional Administrator to request any
information, in addition to that specifically required, that is needed to
evaluate incinerator performance and establish adequate operating conditions.
Rationales for the selection of additional waste parameters are summarized in
2-5
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Table 2-1. The ash content of the waste feed should be determined in order to
specify permit conditions for allowable variations in waste feed. Measurement
of ash content also allows evaluation of potential for slag and particulate
formation. If the waste is solid or sludge, a thermogravimetric analysis
(measurement of weight loss as a function of temperature) provides valuable
information. Knowledge of flash point or explosivity helps to ensure safe
handling of the wastes. Measurement of carbon, hydrogen, sulfur, nitrogen,
phosphorous and oxygen concentrations and the water content of the waste feed
is needed to compute stoichiometric air requirements and evaluate proposed
excess air usage. Measurement of organically bound chloride content is
necessary to evaluate potential emissions of gaseous hydrogen chloride and to
establish permit conditions for allowable variations in waste content.
Analytical methods for measurement of these parameters are provided in Table
2-2.
2.1.3 Analysis Required To Support Exemption
Applicants proposing to burn hazardous wastes that are ignitable,
corrosive, or reactive may qualify for exemption from most of the standards
for incineration, including the performance standards (40 CFR 264.343),
requirements for continuous monitoring (40 CFR 264.347), inspection
requirements (40 CFR 264.347), and limitations on incinerator operating
conditions. Eligibility for the exemption is determined on the basis of
waste composition. Therefore, after completion of the second step in the
waste analyis procedure, the applicant may decide to apply for the exemption.
If so, the permit application will include the waste analysis plan and data
but will not include a trial burn plan. The permit writer must evaluate the
waste analysis information and determine whether an exemption should be
granted.
2-6
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TABLE 2-1
RATIONALE FOR SELECTION OF WASTE ANALYSIS PARAMETERS
Parameters
Rationle
PCB Content
Organically Bound
Chloride Content
Ash Content
Solids Content
Flash Point
Explosivity
Carbon, Hydrogen, Sulfur,
Nitrogen, Phosphorous,
Oxygen, Water Content
Thermogravimetric
Analysis
Cyanide and Sulfide
Incineration of wastes containing more
than 50 ppm PCB is regulated under
40 CFR 761.60.
The organically bound chloride content
is used to compute the hydrogen chloride
removal efficiency and to estimate uncon-
trolled hydrogen chloride emissions.
The ash content of a waste may be
determined to evaluate potential slag
formation, to assess particulate
removal requirements of an air pollu-
tion control system, and to determine
if the ash handling capability of the
system is sufficient.
Knowledge of these values helps to enusre
safe handling of a waste. Explosive
wastes must be detonated in accordance
with the restrictions imposed under
40 CFR 265.382.
Knowledge of the concentraton of these
substances is necessary if stoichiometric
air requirements are computed to corre-
late oxygen concentrations in the stack
gas with excess air usage.
Thermogravimetric analysis helps to char-
acterize wastes by reducing weight loss
as a function of temperature.
Hazardous wastes exhibiting the reac-
tivity characteristic and containing
cyanides or sulfides are not exempt from
compliance with the Subpart 0 require-
ments.
2-7
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TABLE 2-2
ACCEPTABLE ANALYTICAL METHODS FOR WASTE ANALYSIS
Parameter
Heating Value
Chlorine
(Organical ly bound)
Hazardous Metals:
Mercury
Method(s)*
SA A006
SA A004
ASTM 02361, E442
SA A021
SU 7470, 7471
Comments
Methods D2015 and 03826 are applicable to solid wastes
and D240 is applicabe to liquid wastes.
Combuston method, may be combined with determination
carbon, hydrogen and sulfur.
Summary of atomic absorption and ICAP methods.
These methods are based on detection of mercury vapor
of
by
Arsenic
Selenium
Barium
Beryllium
Cadmium
Chromium
Nickel
Thallium
Lead
Si Iver
Antimony
SW 7060, 7061
SW 7740, 7741
SW 7080, 7081.
SW 7090, 7091,
SW 7130, 7131,
SW 7190, 7191,
EPA 218.1
SW 7520, 7521,
SW 7840,
SW 7420,
SW 7760,
7841,
7421,
7761,
EPA 208.1
EPA 210.1
EPA 213.1
7195, 7196,
EPA 249.1
EPA 279.1
EPA 239.1
EPA 272.1
7197
atomic absorption spectrophotometer, and are subject to
interferences. Spiked samples should be analyzed to
establish recovery. Methods involving strong
oxidation, such as ASTM 03223, should be avoided because
of the possibility of explosions. Alternatively, atomic
absorption may be used with a graphite furnace.
Gaseous hydride generation coupled with atomic absorp-
tion detection is recommended. This method is subject
to interferences so spiked samples should be anlayzed to
establish recovery. Colorimetric methods, such as EPA
206.4 or ASTM 03081, should not be used because of
interferences. Alternatively, atomic absorption may be
used with a graphite furnace.
These methods are for direct aspiration, flame, atomic
absorption spectroscopy. Sample preparation should be
performed in accordance with Section 200.1 of the EPA
manual. Generally, the sensitivy achieved with the
graphite furnace techniques is not required with
hazardous waste samples, and the furnace methods are
subject to interferences.
SW 7040, 7041, EPA 204.1
Hazardous Constituents,
including PCS
Kinematic
Viscosity
Percent
Solids
Sulfur
Ash
Flash Point
Carbon and
Hydrogen
Moisture
Sampling and
Analysis Manual
SA A005
ASTM 0445 or 088
ASTM 01888
ASTM 03177, E443
SA A001-A002
ASTM D3174 or D482
ASTM 093, D3278, or
01310
ASTM D3178
SA A001-A002
ASTM D95, 03173
Hazardous constituents listed in Appendix VIII of "art
251 and those in T3ble 1 of 261.24 may be analyzed
by metnods in SW-346.
A variety of methods -ny be employed using /"r-^js types
instruments, including rational, piston, float, ^ibrat-
•ng probe or cap'llary types.
A distinction should be noted between «ater nsol'jb'e
solids and solids not soluble in organic solvents.
Any of a variety of seoaration techmqjes """ay be
employed; vacuum fi'tration, centrifugation, pressure
filtration, etc.
Combustion methods.
03174 is for solid wastes and 0482 is for liquid
wastes.
Methods 093 and 03278 are pursuant to the definition
of ignitable wastes in Section 251.21 of the regulations
01310 provides comparable results.
Combustion method.
095 is a xylene co-disti1lation and is recommended for
most wastes. 03173 and A001-A002 are intended for solid
wastes, but the oven Beating will drive off volatile
compounds in addition to water. D1796 is a centrifuge
method intended for use with liquids.
SA refers to Sampling and Analysis Manual for Hazardous Waste Incineration, First Edition
SW refers to Test Methods for Evaluating Solid Waste, SW-846, Second Edition
ASTM refers to American Society for Testing and Materials Standards
EPA refers to Chemical Analysis of Water and Wastes, EPA 600/4-79-020
2-8
-------
The exemption is available to incinerators burning wastes that are
ignitable, corrosive, or that have any of the reactivity characteristics
listed in 40 CFR 261.23(a)(l), (2), (3), (6), (7), and (8). The applicant
must also demonstrate that the waste contains only insignificant
concentrations of Appendix VIII constituents. The regulation provides for
automatic granting of the exemption to facilities burning ignitable,
corrosive or reactive wastes that have been shown to contain none of the
hazardous constituents listed in Appendix VIII of 40 CFR Part 261 that would
reasonably be expected to be present. In addition, ignitable, corrosive, and
reactive wastes having low concentrations of some Appendix VIII constituents
may be exempted if the Regional Administrator finds that the exemption will
not result in a potential threat to human health and the environment. Wastes
eligible for the exemption include those that are hazardous solely due to any
one of the selected characteristics and those that are hazardous solely due
to any combination of those characteristics. Wastes listed as hazardous in
40 CFR Part 261 due to the presence of toxic constituents, wastes having the
extraction procedure toxicity characteristics (40 CFR Part 261, Appendix II),
and wastes containing significant concentrations of Appendix VIII
constituents are not eligible for exemption.
The first step in determining whether exemption is appropriate should be
verification that the waste or wastes have only those hazardous
characteristics allowed by the regulation: ignitability, corrosivity, or
certain of the reactivity characteristics. If the waste has been
specifically listed as a hazardous waste by EPA (40 CFR Part 261, Subpart D),
the applicant should verify that the Agency's basis for listing the waste as
2-9
-------
hazardous did not include toxicity or the reactivity characteristics of 40
CFR 261.23(a)(4) or (5). Physical/Chemical Methods (SW-846) provides
analytical methods for determining whether the waste has the reactivity
characteristics of 40 CFR 261.23(a)(4) and (5).4
The second step in the decision process requires review of the waste
analysis information to verify that the waste contains only insignificant (if
any) levels of Appendix VIII constituents. This step should involve
examination of the sampling and analytical methods. The methods required for
collecting representative samples are listed in the regulations (40 CFR Part
261, Appendix I) and are discussed, in detail, in SW-846. The permit writer
should refer to SW-846 and determine whether the applicant has used
appropriate sampling techniques.
Analysis of the waste for hazardous constituents should be conducted as
described previously. The applicant need analyze only for those constituents
reasonably expected to be present, and should identify those Appendix VIII
constituents not reasonably expected and provide a brief rationale for
excluding them from the analysis. The analysis should be conducted using the
methods presented in SW-846. If the analysis shows that none of the expected
constituents were present in concentrations sufficient to be detected by the
SW-846 analytical methods, the exemption should be granted.
40 CFR 261.23(a)(4) describes reactive wastes that, when mixed with
water, generate toxic gases, vapors, or fumes in sufficient quantity to
present a danger to human health and the environment. 40 CFR
261.23(a)(5) describes sulfide or cyanide bearing wastes that when
exposed to pH conditions between 2 and 12.5 can generate toxic gases,
vapors, or fumes in sufficient quantity to present a danger to human
health and the environment.
2-10
-------
In the majority of cases, however, several hazardous constituents will
be detected at low levels and the permit writer will need to determine
whether they can be considered "insignificant". Since a waste feed
concentration of 100 parts per million (ppm) represents a practical lower
limit below which detection in the stack gas will be difficult, the permit
writer may use 100 ppm as a standard against which an initial determination
of "significant" or "insignificant" can be made for most toxic compounds.
The exemption probably should not be allowed if any of the Appendix VIII
hazardous constituents are present in concentrations of 100 ppm or greater.
In some cases, the permit writer may find it necessary to deny the
exemption even if hazardous constituents are present in concentrations
lower than 100 ppm. This may occur, for example, if the constituent is
known to be highly toxic. In such cases, provisions should be made during
the trial burn to ensure that verification of 99.99% destruction and
removal efficiency is possible. The trial burn waste may be spiked with
pure chemical in order to increase the concentration of a POHC present at
less than 100 ppm. Alternatively, the volume of the stack gas sample
collected may be increased to ensure that the POHC will be detected during
analysis.
The sample stack gas volume necessary to verify 99.99% destruction and
removal efficiency may be estimated according to the following procedure.
The quantity of waste (in pounds) needed to generate sufficient
quantity of POHC in the stack gas sample can be calculated from the
formula:
W . = Q X 1Q4
454(C)
2-11
-------
where: W = Quantity of waste (Ibs) to generate Q X 104 ug of POHC in
stack gas sample;
C = Concentration of POHC in waste feed (ug/g = ppm); and
Q = Quantity of POHC (ug) needed in the stack gas sample to
ensure detection.
Assuming that 1 standard cubic foot (SCF) of combustion gas is generatec
for every 100 Btu burned at stochiometric conditions, and given the heating
value of the waste and the amount of air fed to the combustion chamber in
excess of stoichiometric requirements, the dry volume of the stack gas
sample, at standard temperature and pressure (68°F or 20°C and 29.92 in Hg]
can be estimated from the formula:
Vs = (W x Hw x A)/100
where: Vs = Dry volume of the stack gas sample at standard
temperature and pressure (dscf):
Hw = Heating value of the waste (Btu/lb); and
A = Air feed to combustion chamber
Stoichiometric Air Requirement
This volume must be corrected to the coresponding volume at stack
conditions and corrected to include the volume of gas generated by burning
auxiliary fuel, as follows:
VD = ((460 + T)/528 x (((Hp x R x W)/100) + Vs)
where: VD = Actual dry volume of stack gas sample (corrected to stack
temperature and for contribution from auxiliary fuel) (dacf);
T = Stack gas temperature (°F);
Hp = Heating value of fuel (Btu/lb) and
R = Fuel Feed Rate
Waste Feed Rate
OR = op + 460QF
2-12
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The dry sample volume must then be corrected to account for water vapor
in the stack gas. After passing through an air pollution control system, the
stack will likely be saturated with water. Figure 2-1 shows the water
content of saturated stack gas as a function of quenched stack gas
temperature. The corrected sample volume is calculated from the formula:
Vw =
where: Vw = Volume of the stack gas sample including water vapor;
and
K = Concentration (volume fraction) of water in the flue gas
(% volume of water/100).
If the flue gas is not quenched, the water content of the flue gas depends on
the waste feed and must be taken into account on a case by case basis.
The utility of this calculation is illustrated by the following example.
A waste feed having the characteristics:
C = Concentration of hexachlorobenzene = 400 ppm
Hw = Waste heating value = 6500 Btu per pound,
will be burned under the following condiitions:
T = Stack gas temperature = 160°
A = Air fed to the combustion chamber = 1.2
Stoichiometric air requirement
R = Fuel feed rate = .20
Waste feed rate
The auxiliary fuel used has a heating value of 19,000 Btu per pound (Hf)
and the flue gas is saturated with water. A quantity of 10 ug of
hexachlorobenzene is necessary in the stack gas sample to ensure
detection. Therefore, the waste burned to generate 10 ug of HCB in the
stack gas, at 99.99% ORE, must contain 1 x 1()5 ug of HCB, and
2-13
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a
e
a
U rj
fl C
O -3
4)
V u
S O
r v-
r-l 3
o "
> a
V3
u
s •
a u
y o
w &
v a
o. >
FIGURE 2-1
WATER VAPOR CONTENT OF SATURATED FLUE GAS
60
80 100 120 140 160 ISO 200 220
Gas Temperature, °F
Basis: Volume of water vapor in saturated air at 1 atm.
2-14
-------
Vs = ((105/(454 x 400)) x 6500 x i.2)/100
= 42.9 dscf
VD = ((460 + 160J/528) x (((19,000 x 0.20 x 0.55)/100) + 4.29)
= 74.9 dacf
K = 0.32 from Figure 2-1, therefore:
Vw = 74.9
1 - 0.32
= 110 acf
Thus, a minimum of 110 acf of stack gas should be collected to ensure
detection of hexachlorobenzene to 99.99% ORE.
2.2 Designating Principal Organic Hazardous Constituents
In accordance with the incinerator regulations, the permit writer must
designate one or more of the organic hazardous constituents identified in the
waste feed as principal organic hazardous constituents (POHCs). The
regulation specifies that POHC selection be based on a consideration of two
factors: the degree of incinerability and the concentration of each organic
hazardous constituent in the waste feed. EPA has therefore developed a
method, presented here for systematic consideration of these two factors in
selecting POHCs.
The method presented uses the heat of combustion of the hazardous
constituent as an indication of incinerability. Constituents having low heat
of combustion values are assumed to be less able to support combustion.
Table 2-3 lists in alphabetical order the organic hazardous constituents from
40 CFR Part 261, Appendix VIII, and provides the heat of combustion
(kilocalories per gram] of each. These same constituents are ranked in
Table 2-4, according to ease of incinerability (i.e., those most difficult to
2-15
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TABLE 2-3
HEAT OF COMBUSTION OF ORGANIC HAZARDOUS
CONSTITUENTS FROM APPENDIX VIII, PART 261
Hazardous Constituent
HC/MW
kcal/gram
Hazardous Constituent
HC/MW
kcal/gram
N)
I
Acetonitrile 7.37
Acetophenone 8.26
3-(alpha-Acetonylbenzyl)-4-hydroxycoumarin 7.00*
and salts (Warfarin)
2-Acetylaminofluorene 7.92*
Acetyl chloride 2.77*
l-Acetyl-2-thiourea A.55*
Acrolein 6.95
Acrylamide 5.75*
Acrylonitrile 7.93
Aflatoxins 5.73*
Aldrin 3.75*
Allyl alcohol 7.75
4-Aminobiphenyl 9.00
6-Amino-1,la,2,8,8a,8b-hexahydro-8-(hydroxy- 5.41*
methyl)8a-methoxy 5-methylcarbamate azirino
(2',3':3,4)pyrrolo(l,2-a)indole-4,7-dione
(ester)(Mitomycin C)
5-(Aminomethy1)-3-isoxazolol 4.78
4-Aminopyridine 7.37*
Amitrole 4.01*
Aniline 8.73
Au ramlne 7.69*
Azaserine 3.21*
Benz(c)acridine 8.92*
Benz(a)anthracene 9.39
Benzene 10.03
Benzenearsonic acid 3.40*
Benzenethiol 8.43
Benzldine 9.18
Benzo(b)fluoranthene 9.25
Benzo(j)fluoranthune 9.25
Benzo(a)pyrene 9.25
Benzoquinone
Benzotrichloride
Benzyl chloride
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
N,N-Bis(2-chloroethyl)-2-naphthylamina
Bis(2-chloroisopropyl)ether
Bis(chloromethyl)ether
Bis(2-ethylhexyl)phthalate
Bromoacetone
Bromomethane
4-Bromophenyl phenyl ether
Brucine
2-Butanone peroxide
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol (DNBP)
Chloral(Trichloroacetaldehyde)
Chlorambucil
Chlordane
Chlorinated benzenes, N.O.S.
Chlorinated ethane, N.O.S.
Chlorinated fluorocarbons
Chlorinated naphthalene, N.O.S.
Chlorinated phenol, N.O.S.
Chloroacetaldehyde
Chloroalkyl ethers
p-Chloroaniline
Ch lorobenzene
Chlorobenzilate
p-Chloro-m-cresol
1-Clil oro-2 ,3-epoxybutane
6.07
3.90*
6.18
4.60*
3.38*
6.64*
4.93*
1.97*
8.42*
2.66*
1.70*
5.84*
7.42
6.96*
8.29*
5.46*
0.80*
5.93*
2.71*
N/A
N/A
N/A
N/A
N/A
2.92*
N/A
6.14*
6.60
5.50*
5.08*
5.19*
-------
Z—J
Hazardous Constituent
HC/MW
kcal/gram
Hazardous Constituent
HC/MW
kcal/gram
t-O
I
2-Chloroethyl vinyl ether 5.19*
Chloroform .75
Chloromethane 3.25
Chloromethyl methyl ether 3.48*
2-Chloronaphthalene 7.37
2-Chlorophenol 6.89
l-(o-Chlorophenyl)thiourea 5.30*
3-Chloropropionitrile 4.50*
Chrysene 9.37
Citrus Red No. 2
Coal tars N/A
Creosote N/A
Cresol 8.18
Cresyllc Acid 8.09*
Crotonaldehyde 7.73
Cyanogen 6.79
Cyanogen bromide .81*
Cyanogen chloride 1.29*
Cycasin 3.92*
2-Cyclohexyl-4,6-dinitrophenol 5.74*
Cyclophosphamide 3.97*
Daunomycin 5.70*
ODD 5.14*
DDE 5.05*
DDT 4.51*
Diallate 5.62*
2,4-D 3.62*
Dibenz(a,h)acrldine 9.53*
Dibenz(a,j)acridine 9.53*
Dibenz(a,h)anthracene(Dibenzo(a,h)anthracene) 9.40*
7H-Dibenzo(c,g)carbazole 8.90*
Dibenzo(a,e)pyrene 9.33"
Dibenzo(a,h)pyrene
Dibenzo(a,i)pyrene
1,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
Di-n-butyl phthalate
Dichlorobenzene, N.O.S.
3,3 '-Dichlorobenzidine
1,4-Dichloro -2-butene
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
trans-1,2-DlchLoroethene
Dichloroethylene, N.O.S.
1,1-Dichloroethylene
Dichloromethane
Dichloromethylbenzene
2,4-Dichlorophenol
2,6-Dichlorophenol
Dichloropropane
Dichlorophenylarsine
1,2-Dichloropropane
Dichloropropanol, N.O.S.
Dichloropropene, N.O.S.
1,3-Dichloropropene
Dieldrin
Diepoxybutane
Diethylarsine
1,2-Diethylhydrazine
Diethyl phthalate
Dihydrosafrole
9.33*
9.33*
1.48*
1.43*
0.50*
7.34*
4.57
5.72*
4.27*
0.22*
3.00
3.00
3.00
2.70
2.70
1.70
5.09*
3.81*
3.81*
3.99
2.31*
3.99
2.84
3.44*
3.44*
5.56*
5.74
5.25*
8.68*
6.39
7.66*
-------
TABLE 2-3 (Continued)
Hazardous Constituent
Hc/MW
kcal/gram
Hazardous Constituent
Hc/MW
kcal/gram
N>
I
H1
00
3,4-Dihydroxy-alpha-(methylamino} -^methyl 6.05*
benzyl alcohol
Dimethoate 4.02
3,3'-Dimethoxybenzidine 7.36*
p-Dimethylaminoazobenzene 6.97*
7,12-Dimethylbenz(a)anthracene 9.61
3,3'-Dijnethylbenzidine 8.81*
Dimethylcarbamoyl chloride 5.08*
1,1-Dimethylhydrazine 7.87
1,2-Dimethylhdrazine 7.87
3,3-Dimethyl-l-(methylthiol-2-butanone-0- 5.82*
(methylamino)carbonyl oxime
Dimethylnitrosoamine 5.14*
alpha,alpha-Dimethylphenethylamine 9.54*
2,4-Dimethylphenol 8.51
Dimethyl phthalate 5.74
Dimethyl sulfate 2.86
Dinitrobenzene, N.O.S. 4.15
4,6-Dinitro-o-cresol and salts 4.06*
2,4-Dinltrophenol 3.52
2,4-Dinitrotoluene 4.68
2,6-DinitroEoluene di-n~octyl phthalate 6.67*
1,4-Dioxane 6.41
Diphenylamine 9.09
1,2-Diphenylhydrazine 8.73*
Di-n-propylnitrosamine 7.83*
Disulfoton 5.73*
2,4-Dithiobiuret 2.12*
Endosulfan 2.33*
Endrin 3.46*
Ethyl carbamate 4.73*
Ethylenebisdithiocarbamate 5.70*
Ethyl cyanide
Ethyleneimine
Ethylene oxide
Ethylenethiourea
Ethyl methacrylate
Fluoranthene
2-Fluoroacetamide
Formaldehyde
Formic acid
Glycidylaldehyde
Halomethane, N.O.S.
Heptachlor
Heptachlor epoxide
Hexachlorobenzene
Hexachlorobu tad iene
Hexachlorocyclohexane (all isomers)
Hexachlorocyclopentadiene
Hexachloroethane
l,2,3,4,10,10-Hexachloro-l,4,4a,5,8,8a-
hexahydro-l,4:5,8-endo, endo-
dlmethanonaphthalene
Hexachlorophene
Hexachloropropene
Hydrazine
Indeno(l,2,3-c,d)pyrene
lodomethane
Isocyanic acid, methyl ester
Isobutyl alcohol
Isosafrole
Kepone
Lasiocarpine
Maleic anhydride
4.57
7.86*
6.86
5.98*
7.27*
9.35
3.24
4.47
1.32
5.74
N/A
2.96*
2.71*
1.79
2.12*
1.12*
2.10*
.46
3.38*
3.82*
0.70*
4.44*
8.52*
1.34
4.69*
8.62
7.62
2.15*
3.40
-------
TABLE 2-3 (Continued)
Hazardous Constituent
Hc/MW
kcaf/gram
Hazardous Constituent
HC/MW
kcal/gram
ho
I
Maleic hydrozide 4.10*
Malononitrile 5,98
Melphalan 5.21*
Methacrylonitrile 8.55*
Methanethiol 5.91*
Methapyrilene 7.93*
Methomyl 5.20*
Methoxychlor 5.59*
2-Methylaziridine 9.09*
3-Methylcholanthrene 9.57*
4,4'-Methylene-bis-(2-chloroaniline) 4.84*
Methyl ethyl ketone (MEK) 8.07
Methyl hydrazlne 6.78*
2-Methyllactonitrile 6.43
Methyl methacrylate 6.52*
Methyl methanesulfonate 3.74
2-Methyl-2-Gnethylthio)propionaldehyde-o- 5.34*
(methylcarbonyl) oxime
N-Methyl-N'-nitro-N-nitrosoguanidine 4.06*
Methylparathion 4.00*
Methylthiouracil 4.79*
Mustard gas 4.06*
Naphthalene 9.62
1,4-Naphthoquinone 6.97
1-Naphthylamine 8.54
2-Naphthylamine 8.54
l-Naphthyl-2-thiourea 7.50*
Nicotine and salts 8.92*
p-Nitroaniline 5.50
Nitrobenzene 5.50
Nitrogen mustard and hydrochloride salt 4.28*
Nitrogen mustard N-oxide and hydrochloride salt 3.56
Nitroglycerine 3.79
4-Nitrophenol 4.95
4-Nitroquinoline-l-oxide 5.59
5-Nitro-o-toluidine 5.98
Nitrosoamine, N.O.S. N/A
N-Nitrosodi-N-butylamine 8.46*
N-Nitrosod iethanolamine 7.02*
N-Nitrosodiethylamine 6.86*
N-Nitrosodimethylamine 5.14*
N-Nltroso-N-ethylurea 3.92*
N-Nitrosomethylethylamine 6.13*
N-Nitroso-N-methylurea 2.89*
N-Nitroso-N-methylurethane 4.18*
N-Nitrosomethylvinylamine 7.91*
N-Nitrosomopholine 5.22*
N-Nitrosonornicotine 7.07*
N-Nitrosopiperldine 7.04*
N-Nitrosopyrrolidine 6.43*
N-Nitrososarcosine 3.19*
7-Oxabicyclo(2.2.1)heptane-2,3-dicarboxylic acid 4.70*
Paraldehyde 6;30*
Parathion 3.61*
Pentachlorobenzene 2.05*
Pentachloroethane 0.53*
Pentachloronitrobenzene(PCNB) 1.62*
Pentachlorophenol 2.09
Phenacetin 7.17
Phenol 7.78
Penylenediamine 7.81
Phenyl dichloroarsine 3.12*
-------
TABLE 2-3 (Cont'd)
Hazardous Constituent
Uc/MW
kcal/graa
Hazardous Conatitueut
Hc/MW
keel/gram
to
I
N>
O
Phenylioercury acetate
N-Phenylthioucea
Phthallc acid eaters, N.O.S.
Phthalic anhydride
2-1'icoline
Polychlorinated biphenyl isomers
Monochloro
Dlchloro
Trlchloro
Tetrachloro
Pentachloro
Uexachloro
Ueptochloro
Octactkloro
Nonachloro
Decachloro
Pronauide
1,3-Propane aultone
n-Propylauilne
Propylthlouracll
2-Propyn-l-ol
PyrlJlne
fteset pine
Resorclnol
Saccharin
Safrole
Strychnnine and salts
2,4.5-TP
2,4,5-T
2.71*
6.93*
N/A
5.29
8.72
7.75*
6.36*
5.10*
A.29*
3.66*
3.2U*
2.98*
2.72*
2.50*
2.31*
5.72*
3.67*
9.58
6.28*
7.43*
7.83
6.70*
6.19
4.49*
7.68
8.03
5.58*
2.87*
1,2,4,5-Tetrachlorobenzene 2.61*
TCDD 3.43*
Tetrachloroethane, N.O.S. 1.39
1,1,1,2-Tetrachloroethana 1.39
1,1,2,2-Tetrachloroetbane 1.39
Tetrachloroetheiie (Tetrachloroethylene) 1.19
Tetrachloromethane (Carbon teCrachloride) 0.24
2,3,4,6-Tetrachloropheuol 2.2J*
Tetraethyl lead 4.04*
Yetranltroaethane 0.41*
Thioacetauide 5.95*
Thiosemicarbazlde 4.55
Thlourea 4.55
Thiuram 5.85*
Toluene 10.14
Toluene dlamlne 8.24*
o-Toluidlne hydrochlorlJe 6.63*
Toluene diisocyanate 5.92*
Toxaphene 2.50*
Trlbromoiuethaae 0.13
1,2,4-Trlcltlorobeuzene 3.40*
1,1,1-Trlcliloroethaue 1.99
1,1,2-Trlchloroetliane 1.99
Trichloroethene (Trlchloroethylene) 1.74
Tricltlorometlianuthlol 0.84*
Trlchloromonofluoro methane 0.11*
2,4,5-Trlctilorophenol 2.88*
2,4.6-Trlcliloropheuol 2.88*
Trlchloropropane, N.O.S. 2.81
-------
TABLE 2-3 (Continued)
Hazardous Constituent
Hc/MW
kcal/gram
Hazardous Constituent
Hc/MW
kcal/gram
1,2,3-Trichloropropane
Trypan blue
2.81
3.84*
Uracil mustard
Vinyl chloride
4.00*
4.45*
*Computed by method of Handrick, Ind. Eng. Che., 48:1366 (1956).
N/A: Not applicable, see individual constituents.
Sources: Lange's Handbook of Chemistry, llth Edition, McGraw-Hill, 1973
Cox and Pilcher, Thermochemistry of Organic and Organo-metallic
Compounds, Academic Press, London, 1970.
-------
TABLE 2-4
RANKING OF INCINERABILITY OF ORGANIC HAZARDOUS CONSTITUENTS FROM
APPENDIX VIII. PART 261 ON THE BASIS OF HEAT OF COMBUSTION
Hatardous Constituent
Heat of
Combustion
keel/gram
Hazardous Constituent
Heat of
Combustion
keel/gram
NJ
to
Trichloromonof luoromathana
Tribromomethane
DlchlorodIfluoroaet hans
Tetrachloromethane (Carbon tetrachloride)
Tetranitrometbane
Uexachloroethane
Dlbromomet hans
Pentachlotoetban*
Hexachloropropene
Chloroform
Chloral ttrlchloroacetaldebydel
Cyanogen bromide
Trichloromethanetiol
Hexachlorocyclobaxane
Tetracbloroetbens (Xetracbloroetbylene)
Cyanogen chloride
Formic acid
lodometbane
Tetracbloroethana, N.O.S.
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
1,2-Dibromomethano
1,2-D Ibromo'O-chloropropane
Fentachloronitrobentene
Bromomethana
Dlchloromethana
Trlchloroethene (Irlchloroethylene)
Hexachlorobenzene
0.11
0.13
0.22
0.24
0.41
0.46
0.50
0.53
0.70
0.75
0.80
0.81
0.84
1.12
1.19
1.29
1.32
1.34
1.39
1.39
1.39
1.43
1.48
1.62
1.70
1.70
1.74
1.79
Bis (chloromethyl) ether
1,1,1-Trlchloroethane
1,1,2-Trichloroethane
Pentachlocobensene
Pentachlorophenol
Uexachlorocyclopentediene
Hexachlorobutadlene
Kepone
2,3,4,6-Tetrachlorophenol
Dichlorophenylarslne
Decachlorobiphenyl
Endosulfan
Nonac hlorob ipheny1
Toxaphene
1,2,4,5-Tetrachlorobeiuene
Bromoscetone
Dlchloroethylene, N.O.S.
1,1-Dichloroethylene
Chlordane
Heptachlor epoxlde
Phenylmercury acetate
Octachlorobiphenyl
Acetyl chloride
Trichloropropane. N.O.S.
1,2,3-Tr ichloropropane
Dichloropropanol, N.O.S.
Dimethyl eulfate
2.4.5-T
1.97
1.99
1.99
2.05
2.09
2.10
2.12
2.15
2.23
2.31
2.31
2.33
2.50
2.50
2.61
2.66
2.70
2.70
2.71
2.71
2.71
2.72
2.77
2.81
2.81
2.84
2.86
2.87
-------
TARLE 2-4 (Continued)
Hazardous Constituent
Heat of
Combustion
kcal/gram
Hazardous Constituent
Heat of
Combustion
kcal/gram
NJ
I
OJ
2,4,5-Trichlorophenoi 2.88
2,4,6-Trichlorophenol 2.88
N-Nitroso-N-methylurea 2.89
Heptachlorobiphenyl 2.98
1,1-Dichloroethane 3.00
1,2-Dichloroethane 3.00
trans-1,2-Dichloroethane 3.00
Phenyl dichloroarsine 3.12
N-Nitrosoarcosine 3.19
Azaserine 3.21
2-Fluoroacetamide 3.24
Chloromethane 3.25
Hexachlorobiphenyl 3.28
Bis (2-chloroethyl) ether 3.38
l,2,3,4,10,10-Hexachloro-l,4,4a,5,7,8a- 3.38
hexahydro-1,4:5,8-endo, endo-
dimethanonaphthalene
Benzenearsonic acid 3.40
Maleic anhydride 3.40
1,2,4-Trichlorobenzene 3.40
TCDD 3.43
Dichloropropene, N.O.S. 3.44
1,3-Dichloropropene 3.44
Endrin 3.46
Chloromethyl methyl ether 3.48
2,4-Dinitrophenol 3.52
Nitrogen mustard N-oxide and hydrochloride 3.56
salt
Parathion 3.61
2,4-D 3.62
Pentachlorobiphenyl
1,3-Propane sultone
Methyl methanesulfonate
Aldrin
Nitroglycerine
2,4-Dichlorophenol
2,6-Dichlorophenol
Hexachlorophene
Trypan blue
Benzotr ichloride
Cycasin
N-Nitroso-N-ethylurea
Cyclophosphamide
Dichloropropane, N.O.S.
1,2-Dichloropropane
Methylparathion
Uracil mustard
Amitrole
Dimethoate
Tetraethyl lead
4,6-Dlnitro-o-cresol and salts
N-Methyl-N -nitro-N-nitrosoguanidine
Mustard gas
Maleic hydrazide
Dinitrobenzene, N.O.S.
N-Nitroso-N-methylurethane
l,4-Dichloro-2-butene
Nitrogen mustard and hydrochloride salt
Tetrachlorobiphenyl
3.66
3.67
3.74
3.75
3.79
3.81
3.81
3.82
3.84
3.90
3.92
3.92
3.97
3.99
3.99
4.00
4.00
4.01
4.02
4.04
4.06
4.06
4.06
4.10
4.15
4.18
4.27
4.28
4.29
-------
TABLE 2-4 (Continued)
Hazardous Constituent
Heat of
Combustion
kcal/gram
Hazardous Constituent
Heat of
Combustion
kcal/gram
to
I
NJ
Hydrazine 4.44
Vinyl chloride 4.45
Formaldehyde 4.47
Saccharin 4.49
3-Chloropropionitrile 4.50
DDT 4.51
Thiourea 4.51
l-Acetyl-2-thiourea 4.55
Thiosemicarbazide 4.55
Dichlorobenzene, N.O.S. 4.57
Ethyl cyanide 4.57
Bis (2-chloroethoxy) methane 4.60
2,4-Dinitrotoluene 4.68
Isocyanic acid, methyl ester 4.69
7-Oxabicyclo (2.2.1) heptane-2,3-dicarboxylic 4.70
acid
Ethyl carbamate 4.73
S-(Aminomethyl)-3-isoxazolol 4.78
Methylthiouracil 4.79
4,4' -Methylene-bis-(2-chloroaniline) 4.84
Bis (2-chloroisopropyl) ether 4.93
4-Nitrophenol 4.95
DDE 5.05
Dimethylcarbamoyl chloride 5.08
p—Chloro-m-cresol 5.08
Dichloromethylbenzene 5.09
Trichlorobiphenyl 5.10
ODD 5.14
Dimethylnitrosoamine 5.14
N-Nitrosodimethylamine 5.14
Diethylarsine ' 5.25
Phthalic anhydride 5.29
l-(o-chlorophenyl) thiourea 5.30
2-Methyl-2-(methylthio) propionaldehyde-o- 5.34
(methylcarbonyll oxime
2-sec-Butyl-4,6 dinitrophenol (DNBP) 5.46
p-Nitroaniline 5.50
Chlorobenzilate 5.50
Dieldrin 5.56
2,4,5-TP 5.58
Methoxychlor 5.59
4-Nitroquinoline-l-oxide 5.59
Diallate 5.62
Daunomycin 5.70
Ethylenebisdithiocarbamate 5.70
3,3'-Dichlorobenzidine 5.72
Pronamide 5.72
Aflatoxins 5.73
Disulfoton 5.73
4,6-Dinitrophenol 5.74
Diepoxybutane 5.74
Dimethyl phthalate 5.74
Clycidylaldehyde 5.74
Acrylamide 5.75
3,3-Dimethyl-l-(methylthio)-2-butanone-0- 5.82
(methylamino)carbonyl oxime
4-Bromophenyl phenyl ether 5.84
Thiuram 5.85
Methanethiol 5.91
Tolylene diisocyanate 5.92
Chlorambucil 5.93
Thioacetamide 5.95
-------
Hazardous Constituent
Heat of
Combustion
kcal/gram
Hazardous Constituent
Heat of
Combustion
kcal/gram
to
I
N3
Ul
Ethylenethiourea
Malononitrile
5-Nitro-o-toluidine
Nitrobenzene
3,4-Dihydroxy-al[.!ha-(methylamino)inethyl
benzyl alcohol
Benzoquinone
N-Nitrosomethyletnylamine
p-Chloroanillne
Benzyl chloride
Resorcinol
Propylthiouracil
Paraldehyde
Dichlorobiphenyl
Diethyl pht'ualate
Dioxane
2-Methyllactonitrile
N-Nitrosopyrrolidone
Methyl methacrylate
Chlorobenzene
o-Toluidine hydrochloride
N,N-Bis (2-chloroethyl)-2-naphthylamine
2,6-Dinitrotoluene di-n-octyl phthalate
Reserpine
Methyl hydrazine
Cyanogen
Ethylene oxide
N-Nitrosodiethylatuine
2-Chloropheno1
N-Phenylthiourea
Acrolein
5.98
5.98
5.98
6.01
6.05
6.07
6.13
6.14
6.18
6.19
6.28
6.30
6.36
6.39
6.41
6.43
6.43
6.52
6.60
6.63
6.64
6.67
6.70
6.78
6.79
6.bb
6.86
b.ay
6.93
6.96
2-Butanone peroxide 6.96
p-Dimethylaminoazobenzene 6.97
1,4-Naphthoquinone 6.97
3-(alpha-Acetonylbenzyl)-4-hydroxycoumarin 7.00
and salts (Warfarin)
N-Nitrosodiethanolamine 7.02
N-Nitrosopiperidine 7.04
N-Nitrosonornicotine 7.07
Phenacetin 7.17
Ethyl methacrylate 7.27
Di-n-butyl phthalate 7.34
3,3'-Dimethoxybenzidine 7.36
Acetonitrile 7.37
4-Aminopyridine 7.37
2-Chloronaphthalene 7.37
2 Propyn-1-ol 7.43
l-Naphthyl-2-thiourea 7.50
Isosafrole 7-62
Dihydrosafrole 7.66
Safrole 7 -68
Auramine 7.69
Crotonaldehyde 7.73
Allyl alcohol 7-75
Monochlorobiphenyl 7.75
Phenol 7.78
Phenylenediamine 7.81
Di-n-propylnitrosoaruine 7.83
Pyridine 7.83
Ethyleneimine 7.86
1,1-Dimethylhydrazine 7.87
1,2-Dimethylhydrazine 7.87
-------
TABLE 2-4 7Continued)
Hazardous Constituent
Heat of
Combustion
kcal/grara
Hazardous Constituent
Heat of
Combustion
Real/gram
I
N>
N-N it ro somet hyIv inylamine
2-Acetylaminofluorine
Acrylonitrile
Methapyrilene
Strychnine and salts
Methyl ethyl ketone (MEK)
Cresylic acid
Cresol
Toluene diamine
Acetopheaoue
Butyl beii/yl phthalate
Ethyl cyanide
Bis (2-ethylhexyl) phthalate
Benzenethiol
N-Nitrosodi-N-butylamine
2,4-Dimettiyl phenol
Indciiol (l,2,3-c,d) pyrene
Diethylstilbestrol
1-Naphthylainine
2-Naphthylamine
Methacrylonitrile
Isobutyl alcohol
1,2-DietU> Lhydraz ine
2-Picoline
Aniline
1,2-Diphenylhydraz ine
7.91
7.82
7.93
7.93
8.03
8.07
8.09
8.18
8.24
8.26
8.29
8.32
8.42
8.43
8.46
8.51
8.52
8.54
8.54
8.54
8.55
8.62
8.68
8.72
8.73
8.73
3,3 '-Dimethoxybenzidine
7H-Dibenzo Cc,g) carbazole
Benz Cc) acridine
Nicotine and salts
4-Amino biphenyl
Diphenylamine
2-Methylaziridine
Benzidine
Benzo (b) fluoranthene
Benzo (j) fluoranthene
Benzo (a) pyrene
Dibenzo (a,e) pyrene
Dibenzo (a,h) pyrene
Dibenzo (a,i) pyrene
Fluoranthene
Benz (a) anthracene
Dibenz (a,h) anthracene (Dibenzo Ca,h)
anthracene)
Dibenz (a,h) acridine
Dibenz (a,j) acirdine
alpha, alpha-Dimethylphenethylamine
3-Methylcholanthrene
n-Propylamine
7,12-Dimethylbenz (a) anthracene
Naphthalene
Benzene
Toluene
8.81
8.90
8.92
8.92
9.00
9.09
9.09
9.18
9.25
9.25
9.25
9.33
9.33
9.33
9.35
9.39
9.40
9.53
9.53
9.54
9.57
9.58
9.61
9.62
10.03
10.14
-------
Incinerate, as indicated by their low heat of combustion values, are listed
first).5
To select POHCs for a given waste feed, the permit writer should array
the hazardous constituents and their concentrations in order of increasing
incinerability (i.e., the order in which they appear on Table 2-4). The
least incinerable constituent (i.e., that constituent having the lowest heat
of combustion value) and the most abundant constituent should be designated
as POHCs. In theory, only one POHC need be designated on the basis of
incinerability. The correlation between heat of combustion and
incinerability, however, is approximate. Therefore, more than one POHC
should be designated on the basis of incinerability in most cases,
particularly when the heat of combustion values indicate only small
differences in incinerability. Overall, POHC selection should be limited to
no more than six constituents.
Several methods have been proposed to measure incinerability. Among the
parameters that have been suggested for developing a hierarchy are the auto-
ignition temperature of the hazardous constituents, chemical kinetic rate
constants for oxidation reactions, and the heats of combustion of the
constituents. Applicants may use other parameters to establish a hierarchy.
Rather than deciding whether an applicant's method of ranking incinerability
is valid, which may not possible due to the limited amount of data available,
the permit writer may require that several POHCs be selected from among two
or more of the incinerability ranking systems. This approach provides the
The correlation between incinerability and heat of combustion is an
approximation. A^> c'^A 3ccu.>iu i-tes data regarding incinerability, the
hierarchy (Table 2-4) will be adjusted to reflect actual observations.
2-27
-------
best test of incinerator performance and minimizes the errors present in any
POHC ranking system. The applicant should include all data used to make POHC
selections if the heat of combustion hierarchy is not used.
The permit writer should also consider the limitations of stack gas
sampling and analytical techniques when selecting POHCs. Constituents
present in the waste feed in concentrations as low as 1,000 parts per million
(ppm) should be routinely detected in the stack gas. A waste concentration
of 100 ppm represents a practical lower limit below which determination of
99.99% destruction and removal efficiency will be difficult to document.
Whenever possible, POHC selection should be confined to constituents
present in concentrations greater than 100 ppm. In cases where this is not
possible, modification of the stack sampling and analytical methods may be
necessary and the permit writer should determine that the methods described
in the trial burn plan will be adequate. In cases where a POHC is selected
that subsequently is not detected in the stack gas, despite careful
fulfillment of the sampling, analysis and quality control procedures set out
in the trial burn plan, attainment of ORE to the level of detectibility
should be assumed.
When the trial burn plan proposes using a waste that contains one or
more of the POHCs in low concentrations, the permit writer should estimate
the volume of the stack gas sample necessary to detect the POHC present in
low concentrations according to the method presented in Section 2.1.3. Once
this estimate is made, the permit writer can evaluate the adequacy of the
proposed sampling and analytical methods and recommend modifications, as
necessary.
2-28
-------
The following examples demonstrate application of the POHC selection
criteria:
EXAMPLE 1
HAZARDOUS CONSTITUENT % CONCENTRATION HEAT OF COMBUSTION
Chloroform 3 .75
Dichloroethane 14 3.00
Dichlorobenzene 8 4.57
Chlorophenol 12 6.89
Using the POHC values, chloroform should be designated a POHC. Because the
method is an approximation, there is probably no difference in the
incinerability of the other three constituents. At least one of the other
constituents should be designated a POHC in case a 99.99% ORE is not achieved
for chloroform or because of possible errors in the ranking system.
EXAMPLE 2
HAZARDOUS CONSTITUENT % CONCENTRATION HEAT OF COMBUSTION
Chlorobenzene 6 6.60
Phenol 4 7.78
Benzene 4 10.03
Toluene 25 10.14
Using this method, toluene should be designated a POHC because it is present
in the waste at a high concentration, even though it is relatively easy to
incinerate. It is recommended that Chlorobenzene be designated as an
additional POHC in order to demonstrate that the least incinerable organic
hazardous constituent is destroyed. In this example, the use of POHC value
is inconclusive and other data may be used to select POHCs.
2-29
-------
EXAMPLE 3
HAZARDOUS CONSTITUENT % CONCENTRATION HEAT OF COMBUSTION
Tetrachloromethane .001 .24
(Carbon/etrachloride)
Chloromethane 8 3.25
Dichloropropene 8 3.44
Using this method, tetrachloromethane should be designated a POHC. However,
because it is present in the waste in such low concentration, there may be
some difficulty in stack monitoring for this species. Either
dichloropropene, chloromethane, or both should also be designated as POHCs to
ease sampling and analysis problems.
2.3 Review Of The Trial Burn Plan
The trial burn is essentially a test to determine whether an incinerator
is capable of meeting the performance standards and, if it does, to identify
the operating conditions necessary to ensure that the performance standards
will be met. The results of the trial burn directly influence the decision
to issue a permit and the conditions of the permit. Careful and detailed
planning of the trial burn is therefore necessary.
In its final form the trial burn plan should represent the interests of
both the applicant and the permit writer. The data and information generated
during the trial burn should be sufficient to allow the permit writer to
establish permit conditions that provide enough latitude for the facility
operator to accomodate some reasonable variations in waste composition and
incinerator operating conditions. The facility operator may use the trial
burn to identify a range of operating conditions within which the incinerator
2-30
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can achieve the required level of performance, thus allowing the operator
the opportunity to optimize the incinerator operation within the required
level of performance.
Table 2-5 lists the information required to be included in the trial
burn plan. The table may be used as a checklist for purposes of determinng
whether the applicant has included the minimum amount of information in the
trial burn plan. This completeness check should always be the first step in
reviewing the trial burn plan. Because the permit application for a new
incinerator must be filed and a permit issued before construction begins,
some of the information, such as waste composition data, may need to be
updated before the trial burn is conducted. Similarly, specific analytical
methods used in the trial burn may need to be updated or dates and schedules
for the trial burn may require revision. Permit conditions should provide
sufficient flexibility to allow such changes. A careful description of the
expected variations will reduce the need for future major permit
modifications requiring new public hearings.
2.4 Evaluating The Design Of The Trial Burn
In designing the trial burn, the primary goal of both the applicant and
the permit writer should be to identify the conditions under which the
incinerator must be operated in order to successfully treat the designated
principal organic hazardous constituents. The waste -fed to the incinerator
and the operating conditions tested, therefore, are critical components of
the trial burn plan. Because the results of the trial burn directly
influence the conditions of the final operating permit and because
modification of the final permit can be costly and time consuming, the waste
2-31
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TABLE 2-5
CHECKLIST FOR CONTENT OF TRIAL BURN PLANS
Waste Analysis Data
Heating value of the waste
Viscosity (if applicable)
Concentrations of hazardous constituents listed in 40 CFR 261,
Appendix VIII expected to be present in the waste
Organically bound chlorine content (recommended but not required)
Ash content (recommended but not required)
Incinerator Design Information
Manufacturer's name and model number of major incinerator components
Type of incinerator (rotary kiln, liquid injection, etc.)
Linear dimensions of major incinerator components and cross
sectional area of the combustion chamber(s)
Description of auxiliary fuel system
Capacities of prime movers
Description of automatic waste feed cutoff system(s)
Stack gas monitoring and pollution control monitoring systems
Nozzle and burner design
Construction materials
Location and description of temperature, pressure and flow
indicating and control devices
2-32
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TABLE 2-5 (Continued)
Provisions for Sampling and Monitoring of the Incineration Process
Description of process monitoring equipment, procedures, and
locations for:
Combustion zone temperature
Waste and fuel feed rates
Combustion gas velocity
Carbon monoxide in stack gas
Oxygen in the stack gas
Computation of ORE, including methods for sampling and analysis of;
• POHCs in the stack gas,
• Stack gas volume flow rate and temperature
• Waste feed rate and POHC concentrations in waste feed
Determination of particulate emissions, including methods for
measuring:
o Particulates
o Volume flow rate of stack gas
o Temperature of stack gas
o Water content of stack gas
o Oxygen concentration in stack gas
o Metals
Determination of scrubber efficiency including sampling and
monitoring of stack gas for hydrochloric acid if emissions are
greater than 4 pounds per hour
Trial burn Schedule
Dates of trial burn
Duration of trial burn
Quantity of waste feed to be burned
2-33
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TABLE 2-5 (Concluded)
Trial Burn Protocol
Planned operating conditions for each performance burn including:
• Combustion zone temperature
• Waste feed rate
• Combustion gas velocity
• Use of auxiliary fuel and feed rate
• Carbon monoxide level in the stack gas
Planned operating conditions for air pollution control devices
Procedures for stopping waste feed, shutting down the incinerator,
and controlling emissions in the event of an equipment malfunction
or other emergency
2-34
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feed and operating conditions tested should be selected on the basis of a
careful consideration of many facility-specific factors.
The applicant should attempt to account for any planned or possible
changes in the waste feed when designing the trial burn. By selecting
additional POHCs (particularly those that are known to be difficult to
incinerate) or testing a wide range of operating conditions, the applicant
may build sufficient flexibility into the final permit conditions to account
for future changes in waste feed. In this manner, careful planning of the
trial burn can reduce or even eliminate the need for further permit
modifications and trial burns.
2.4.1 Selecting The Trial Burn Waste Feed
The specification of waste composition in a permit is developed
primarily from the values of three parameters, specifically, the heating
value of the waste, the organically bound chloride content, and the ash
content. Other parameters may be used as agreed upon by the permit writer
and the applicant. Relying on the three primary parameters, the applicant
has several options to ensure tha the permit covers most of the wastes that
will be incinerated at the facility.
The trial burn waste feed may take one of three forms: (1) the
applicant may choose to burn the actual waste, or a mixture of actual
wastes, normally accepted for treatment at the incinerator, (2) the
applicant might choose to add hazardous constituents to the actual waste
feed or may increase the concentration of constituents already present in
the waste feed, (3) and the applicant may create an artificial waste feed by
feeding a mixture of chemicals to the incinerator. The chemicals included
2-35
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in such a "waste" feed should be those that are selected as POHCs on the
basis of waste analysis data.
Burning actual waste during the trial burn has the advantages of using
materials that are readily available and providing data that are descriptive
of normal operation. One option is to group wastes with similar
characteristics and to demonstrate that each waste mix can be incinerated at
specific operating conditions. The utility of this approach is best
illustrated by a simplified example. An off-site liquid injection
incinerator operator receives chlorinated solvents from eight generators and
non-chlorinated solvents from four generators. Rather than conduct trial
burns on each of 12 different wastes, the applicant may wish to group the
chlorinated and the non-chlorinated wastes separately, and conduct a trial
burn using the two waste mixes. In order to achieve the greatest benefit
from waste grouping, the applicant should conduct a trial burn at the least
incinerable composition, specifically, at the lowest heating value and the
highest ash and chloride contents of each waste mix.
Using actual waste in the trial burn also has several disadvantages.
Chemical analysis of both the waste and the stack gas may be complicated due
to interference by waste constituents other than the POHCs. Most
importantly, when actual waste is used, the applicant is restricted to
testing only the hazardous constituents present in the waste. The permit,
therefore, will allow burning of only those constituents more easily
incinerated than the most difficult to incinerate constituent in the waste.
If, after the permit is issued, the operator receives a waste containing a
less incinerable constituent, an additional trial burn and major
modification of the permit will be necessary.
2-36
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Spiking the waste with less incinerable hazardous constituents provides
the advantage of increasing the number of hazardous constituents that can be
allowed by the permit. The permit writer should assume that if an
incinerator can achieve a 99.99% ORE of a hazardous constituent, then it is
also capable of achieving a 99.99% ORE of more easily incinerated
constituents, if the same operating conditions are maintained. For example,
it the applicant spikes the waste with chloroform or tribromomethane and
99.99% ORE is achieved, the permit may be written to allow burning of nearly
all of the Appendix VIII hazardous constituents. Spiking the waste to
increase the concentration of constituents already present will increase
stack gas concentrations and reduce sampling and analytical difficulties.
Generally, spiking the actual waste for use in the trial burn allows the
applicant to compensate for the disadvantages of using actual waste and can
be done without causing significant changes in characteristics such as
physical state of the waste and particulate load.
Alternatively, the applicant may propose to incinerate a blend of
chemicals and fossil fuel during the trial burn instead of actual waste.
This approach is useful for new incinerators, particularly when waste will
not be available at the time of the trial burn. When an artificial waste
feed is used, the feed should be blended to contain the POHCs in
concentrations equal to or greater than those expected during routine
operation.
Using an artificial waste feed has the advantage of simplifying the
analytical procedures because interference by organics other than the POHCs
2-37
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is greatly reduced. This approach also allows the applicant to create waste
feed that is very difficult to burn. A successful trial burn conducted
with such a waste feed results in permit conditions allowing the operator to
accept a wide variety of wastes for treatment, perhaps eliminating any
future need for permit modifications and additional trial burns. Operators
of off-site commercial incinerators will generally need such latitude in the
permit in order that they not be restricted in their ability to accept new
clients. Use of wholly artificial waste feeds for the trial burn need not
be restricted to new incinerators or cases where actual waste will not be
available.
Conducting the trial burn with an artificial waste feed may add
complexity to the trial burn plan. The artificial feed may be dissimilar to
actual waste feed in physical state, heating value, chloride content, or ash
content. When an artificial waste feed is used, data must be generated to
document compliance with both the hydrogen chloride removal standard and the
standard for control of particulate emissions. A variety of materials may
be used to test compliance with the particulate emission standard. The
advantages and disadvantages of the use of a limited number of materials are
listed in Table 2-6. If available, incinerator fly ash should be used.
Sand should not be used as a substitute for ash because it forms a slag
layer in the combustion zone and contributes very little to flue gas
particulate load. Ash from combustion of coal acts similarly because of its
high silica content (40-60%). Diatomaceous earth and powdered gypsum or
limestone will be entrained in the flue gas because of their small particle
2-3 8
-------
TABLE 2-6
ADVANTAGES AND DISADVANTAGES OF
MATERIALS TO INCREASE WASTE ASH CONTENT
Material
Advantages
Disadvantages
Sand
ISJ
I
CO
VD
Coal Combustion
Similar to ash of wastes with high
silicate content
Readily available
Will contribute some entrained
particulates
Readily available
Routinely added to rotary kilns
to form protective slag layer
Contributes very little entrained
particulates - forms slag
Not representative of metallic
oxide ash
High silica content (40-60%)
Added to rotary kilns to form
protective slag layer
Metallic oxides are primarily
iron and aluminum
Diatomaceous Earth May be present in some hazardous wastes
or Filter Aids (filter cakes)
Small particle sizes ensure entrainment
in flue gas
Relatively expensive
Chemical composition may not be
representative of incinerator ash
Will not form slag
-------
TABLE 2-6 (Concluded)
ADVANTAGES AND DISADVANTAGES OF
MATERIALS TO INCREASE WASTE ASH CONTENT
Material
Advantages
Disadvantages
•PN
O
Incinerator Fly Readily available
Ash
Will be entrained in flue gas
Will not form slag
Chemical composition representative
of waste ash
Gypsum and Limstone May be entrained in flue gas
Will not form slag
May have to be dewatered or
dried
Must be powdered ( 100 mesh)
Chemical compositon not repre-
sentative of waste ash
(CaS04 2H20 = gypsum, CaO =
limestone)
Not likely to be present in
hazardous wastes
-------
sizes. These materials will not form a slag in the combustion chamber, but
are very different in chemical composition from incinerator fly ash.
Materials containing organically bound chloride may be added to an
artificial waste feed in order to test the efficiency of the gas scrubbing
equipment. Hydrogen chloride removal efficiencies generally increases as
the hydrogen chloride content of the influent gas stream increase, until the
scrubber capacity is exceeded. The applicant may attempt to establish the
maximum organically bound chloride concentration in the waste that the
device can effectively control.
2.4.2 Operating Conditions
The results of the trial burn are the permit writers' principal basis
for setting the conditions of the operating permit. It is therefore
necessary that the data and information collected during the trial burn
provide an accurate description of incinerator performance and operation.
The trial burn data should identify a range of values for each operating
parameter required by the standards, specifically: carbon monoxide level in
the stack gas, waste feed rate, total thermal input rate, combustion
temperature, and combustion gas flow rate within which the incinerator
achieves the performance standards. The trial burn data should provide an
indication of the effect on performance, particularly the destruction and
removal efficiency, that results from a change in one or more of the
operating parameters. For facilities that burn several wastes or waste
mixes specific operating conditions may be associated with specific waste
feed compositions.
2-41
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At facilities where wastes from many sources are blended to make up the
incinerator feed, the applicant might propose to burn several different
waste blends during the trial burn and establish permit conditions for
burning each blend. For example, those wastes that contain hazardous
constituents from the upper third of the incinerability hierarchy (Table 2-
3) might constitute one blend, the most difficult to incinerate. Wastes of
moderate incinerability may be blended into a second waste blend, and wastes
that are relatively easy to incinerate could make up a third blend.
Presumably, the applicant could use the trial burn to identify a set of
operating conditions for each blend, to be established as permit conditions.
The operator would therefore be required to operate at the most stringent
conditions only when burning the least incinerable blend. Temperature and
auxiliary fuel could then be cut back when more easily incinerated blends
are fed.
Conducting this type of trial burn is advantageous to the applicant
because the resulting permit conditions can be sufficiently flexible so as
not to disrupt normal operating practices or significantly increase
operating costs. The cost of conducting the trial burn, however, increases
as the plan becomes more complex. Therefore, decisions regarding the range
of operating conditions to be tested and the number of waste blends to be
burned during the trial burn should be suggested by the applicant.
Determination of the residence time of the waste in the combustion zone
is not specifically required by the incinerator standards. Instead, control
over residence time is established indirectly through the requirement for
monitoripg and controlling combustion gas flow rate and temperature. When
2-42
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the incinerator design includes multiple waste feed locations and multiple
combustion chambers, sufficient residence time can be ensured by specifying
an allowable feed location for each waste feed. The effects of specifying
allowable feed locations on the trial burn plan structure may be determined
from the example presented in Section 4.1.2.
At a minimum, the trial burn plan should propose operation at one set
of steady state6 operating conditions. The plan should specify intended
steady state values for each operating parameter: carbon monoxide level in
the stack gas, waste feed rate, combustion temperature and combustion gas
flow rate. Maintenance of steady state conditions is essential to obtaining
meaningful trial burn results. The applicant should be encouraged to
operate the incinerator at the maximum thermal input and waste feed rates
during a trial burn in order to ensure the greatest flexibility in permitted
operation.
If the applicant proposes to continuously incinerate one waste stream
that does not vary significantly in composition (i.e., the organic hazardous
constituents remain the same, although concentrations may vary slightly), a
simple trial burn plan may provide all of the information necessary. If
compliance with the performance standards is not achieved, however, the
applicant will be required to conduct an additional trial burn.
Furthermore, if compliance is shown at only one steady state, the resulting
permit conditions will restrict operation to those conditions. Therefore,
Steady state occurs when the value of a measured parameter does not
significantly change.
2-43
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the applicant should consider testing performance at the most severe and
most lenient expected operating conditions, and possibly at intermediate
conditions as well. Such operation will allow identification of the
greatest range of acceptable incinerator capabilities and operating
flexibility.
Testing a range of operating conditions will be particularly important
when the incinerator is new and has not been previously evaluated. In cases
where the incinerator has been in operation under interim status and the
operator is reasonably certain that 99.99% destruction and removal
efficiency will be achieved, the trial burn plan may propose to test only
those conditions under which the incinerator is normally operated. The
applicant, however, should view the trial burn as a opportunity to test
various operating conditions and determine whether operating costs can be
reduced (e.g., by reducing combustion temperature, increasing waste feed
rate, or reducing use of auxiliary fuel) without decreasing the level of
performance.
The permit writer's evaluation of the trial burn plan should focus on
determining whether the applicant has provided all of the necessary
information, whether the methods used for sampling and analysis are
equivalent to those of SW-846, and whether the data generated are likely to
establish that the incinerator is capabable of achieving the performance
standards.
2.4.3 Provisions For Stack Gas Sampling And Monitoring
Comprehensive sampling and monitoring during the trial burn is
essential for documenting compliance with the performance standards and for
2-44
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developing the conditions of the permit. At a minimum, sampling and
monitoring data from the trial burn must be sufficient to provide for: a
quantitative analysis of the POHCs in the waste feed to the incinerator; a
quantitative analysis of the exhaust gas for the concentration and mass
emissions of the POHCs, oxygen (02), and hydrogen chloride (HC1); a
quantitative analysis of the scrubber water (if any), ash residues, and
other residues for the POHCs; a computation of destruction and removal
efficiency (ORE); a computation of HCl removal efficiency (if emissions
exceed 1.8 kilograms per hour); a computation of particulate emissions; an
identification of soures of fugitive emissions; a measurement of average,
maximum, and minimum combustion temperature and gas velocity; and a
continuous measurement of carbon monoxide in the exhaust gas (40 CFR
122.27(b)(vi)). When evaluating the trial burn plan, the permit writer
should ensure that provisions for all required sampling and monitoring are
included.
In addition to the sampling and monitoring specifically required, the
permit writer should consider requesting that other parameters be measured.
Combustion gas temperature at the point of entry to the air pollution
control system may be routinely monitored by the applicant to ensure proper
operation of the system. Flow rates for auxiliary fuel and scrubber liquid
might also be monitored to further ensure that proper operating conditions
are maintained.
The trial burn plan should include descriptions of process monitoring
equipment, sampling frequencies, and procedures. The location of each
2-45
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sampling and monitoring point should be indicated on the facility diagram.
Typical sampling and monitoring locations are indicated in Figures 2-2 and
2-3, diagrams of a liquid injection incinerator and a rotary/kiln
afterburner incinerator, respectively. Section 5.6 of the Engineering
Handbook for Hazardous Waste Incineration (1) provides information
concerning the use and capabilities of available monitoring devices.
2-46
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STACK GAS MONITORING FOR:
NJ
I
AUXILIARY
Liouin
FUEL
STORAGE
PARTICIPATES
CURRENT
,, DRAWo
COMBUSTION (J
AIR BLOWER \J
AIR FEED
RATE
J C
• rH
i • L
[VWTURI
SCRUB-
BER
REQUIRED MONITORING IN NEGATIVE LETTERING
AP
• f
AP
. PRIME
>_...... ,M ...J MOV5R
V.'
AP
MASTEWATER
TREATOKNT
FIGURE 2-2
SCHEMATIC DIAGRAM SHOWING TRIAL BURN MONITORING
LOCATIONS FOR A LIQUID INJECTION INCINERATOR
-------
STACK CAS MONITORING
PARTICULATES
•Ji.
CO
CURRENT
DRAW
,,™
PRIME
MOVER
REHEAT
TACK
REQUIRED MONITORING IN NEGATIVE LETTERING
FIGURE 2-3
SCHEMATIC DIAGRAM SHOWING TRIAL BURN MONITORING
LOCATIONS FOR A ROTARY KILN INCINERATOR
-------
3.0 EVALUATION OF INCINERATOR PERFORMANCE DATA
Compliance with the regulatory performance standards may be demonstrated
using data obtained from trial burns, from incineration conducted during
Interim Status, or from incineration conducted at a facility similar to the
applicant's (see Chapter 1). Prior to evaluating data submitted in lieu of
performing a trial burn, the permit writer must determine whether such data
are applicable and similar to the incineration proposed in a permit
application. Methods to determine the similarity of the previous and
proposed incineration are presented in Section 3.1.
Permit applicants may provide many types of incineration performance
data. There is no standard format for the submittal. Because permit
conditions will be established from the data, the permit writer must be able
to accurately interpret the information as provided by the applicant.
Guidance for determination of the sufficiency of engineering data is provided
in Section 3.2.
This chapter contains sample calculations for computation of destruction
and removal efficiencies (ORE), particulate concentrations in the stack gas,
and scrubber efficiencies to check compliance with the regulatory performance
standards. Various factors affecting the calculations are identified in
Sections 3.3, 3.4 and 3.5.
3.1 Evaluation of Data Submitted in Lieu of Trial Burn Results
When evaluating performance data submitted in lieu of trial burn
results, the permit writer should make the following determinations:
t Similarity of previous and proposed wastes
• Similarity of previous and proposed incinerator units
3-1
-------
These determinations should be made prior to checking the calculations
of the incinerator performance results.
3.1.1 Similarity of Wastes
Prior to evaluating the waste analysis data submitted from previous
incineration, the permit writer should ascertain that the waste previously
incinerated is similar to the waste described in the permit application. If
available data are so incomplete as to preclude comparison between the
previous and proposed wastes, then the wastes should be considered
dissimilar and performance data from the applicant's incinerator should be
requested.
Suggested criteria for determination of waste similarity have been
developed to ensure that the applicant's waste or mixture of wastes is as
easily or more easily incinerated than the waste previously destroyed. In
order for the proposed waste and the previously incinerated wastes to be
considered similar, it is suggested that the criteria listed below be met.
t Heating Value - The heating value of the proposed waste must be
equal to or higher than that of previously incinerated waste.
• Hazardous Constituents - The proposed waste must not contain any
hazardous constituents considered more difficult to incinerate than
those in the previously incinerated waste on the basis of the heat
of combustion hierarchy. The use of other incinerability
hierarchies is discussed elsewhere in this manual.
9 Organic Chlorine Content - The organically bound chlorine content
of the proposed waste must be equal to or lower than that of the
previously incinerated waste.
• Ash Content - The ash content of the proposed waste must be equal
to or lower than that of the previously incinerated waste.
3-2
-------
Small increases in chloride and ash content may be allowed if the
permitting official, in his best engineering judgement, finds that there is
insignificant risk in not meeting the required standards. If all of these
criteria are not satisfied, the wastes may not be similar and there is no
basis for comparing the proposed and previous incineration. In cases of
non-similarity, the permit writer should request the applicant to submit
performance data from the incinerator for which a permit is sought.
3.1.2 Similarity of Incinerator Units
The incinerator unit design and operating data should enable the permit
writer to compare the unit previously used to obtain operating data with the
incinerator unit described in a permit application. It is, therefore,
necessary that the data for the previous unit be as detailed as the data
submitted for the proposed unit in order to determine similarity.
Criteria are presented in Table 3-1 for determining the similarity
between the applicant's incinerator unit and the unit previously used for the
incineration of a similar waste. If the previous incineration was conducted
at the applicant's facility, and if the incinerator unit has not been
modified, then this evaluation is not necessary. For the cases in which
this evaluation is necessary, all the criteria in Table 3-1 should be
satisfied for the units to be considered similar. The criteria are designed
so that similarity means that the capabilities of an applicant's incinerator
to destroy a hazardous waste are nearly identical or superior to the
capabilities of the incinerator previously used. If only some of the
requirements are met, the units should be considered dissimilar and the
permit writer should request the applicant to conduct a trial burn. A
3-3
-------
TABLE 3-1
CRITERIA FOR DETERMINATION
OF INCINERATOR SIMILARITY
Parameters
Criteria
for Similarity
Rationale
Type Proposed incinerator should be
the same type as the previous
incinerator
Components and Proposed incinerator combustion
Dimensions zone volume and cross sectional area
+207= of the previous incinerator.
Corresponding linear dimensions
of major components should con-
form within +10%
No method exists to correlate data
from one type of incinerator with
that of another type
The effects of different incinera-
tor geometries on factors such as
turbulence are difficult to quanti-
fy. It is assumed that similar
performance may be expected from
geometrically similar incinerators
Combustion zone
temperature
Proposed incinerator should
operate no less than 20°C below
and no more than 200°C above the
previous incinerator
Ensure same degree of destruction
of hazardous constituents. Prevent
failure of refractory structure
Residence time Proposed incinerator should be
no less than 5% below and no
more than 100% above that of
the previous incinerator
Prevent decreased mixing of combus-
tibles in the proposed incinerator
at 5% below that of the previous
incinerator; at 100% above, the
incinerator designs are not the same
Excess Air or ratio
of air feed rate to
waste feed rate
Proposed excess air should be
equal to the previous incinera-
tion or no more than 50% greater.
The ratio or air/waste feed rates
should not differ by more than 10%
Maintain similarity in design perfor-
mance, temperature and residence time
for purposes of comparison
Air Pollution Control
Devices (APCD)
Devices on the proposed incinera-
tor should be of the same type
(APCD Type as defined in Table
D-2) as those on the previous
incinerator. Liquid to gas ratios
should be within +20%
It is difficult to predict whether
the same degree of performance
will be obtained with different
types of APCD
Auxiliary Fuel Use
Same auxiliary fuel should be used
with ratios of waste/fuel feed
rates not differing by more than
5%
Different fuels will interact
differently with wastes during
combustion. Different fuels
require different air feed rates
3-4
-------
detailed analysis of similarity could be complex and involve design and
operation criteria which are not included in Table 3-1.
3.2 Interpretation of Engineering Data
The permit writer has two major purposes for interpreting engineering
data, specifically to ensure that steady state conditions were achieved
during the incinerator performance test and to determine the range of normal
operating conditions. The permit writer must have the records of
continuously monitored parameters in order to make these determinations. If
an applicant specifies only average or median values of parameters monitored
during a performance test, the permit writer should request the data from
which the values were derived. Instead of presenting detailed methods for
data evaluation in this manual, the permit writer may refer to the example
of data interpretation presented in Chapter 5 and may seek technical
assistance from available resources.
3.3 Calculation of Destruction and Removal Efficiency (ORE)
Incinerators burning hazardous waste must achieve a ORE of 99.99
percent for each principal organic hazardous constituent (POHC) in the waste
feed as required under 40 CFR 264.343(a). The ORE is determined from the
following equation:
ORE = ((Win - W0ut)/Win) * 100
Where: W-jn = Mass feed rate of the principal organic hazardous
constituent (POHC) in the waste stream feeding the
incinerator
Wout = Mass emission rate of the principal organic
hazardous constituent (POHC) present in exhaust
emissions prior to release to the atmosphere.
3-5
-------
The waste feed rate is expressed in mass per unit time and must be consistent
with the units used to express W0ut. If a waste is co-fired with auxiliary
fuel, the auxiliary fuel feed rate does not affect the calculation of win,
unless the fuel contains the POHC.
Wout is calculated from stack sampling data and involves three steps:
t Computation of stack gas sample volume
• Computation of POHC concentration in stack sample
• Computation of stack gas volume flow rate
Stack gas sample volume and stack gas volume flow rate may be determined
either by EPA Methods 2 and 5 in 40 CFR 60, or ASTM Method D2928(2).
Monitoring stack emissions for POHCs includes sampling and analysis of
particular matter, gas phase organics, and water present in the stack gas.
Methods of stack sampling and laboratory analysis for POHCs are presented in
the Sampling and Analysis Manual^). Ideally, all sampling and analytical
data should be included with a permit application. Table 3-2 identifies the
necessary data and provides a method of computation allowing the permit
writer to check the ORE calculated by an applicant. A sample calculation of
ORE is presented in Table 3-3.
If the ORE in the example presented in Table 3-3 were 99.985%, it could
not be rounded off to 99.99%. In developing this guidance manual, the EPA
decided to restrict rounding for two reasons:
1. Rounding a ORE value of 99.985% to 99.99% would allow 50% more
emission of a POHC than the standard would allow without any
rounding. The example in Table 3-3 can be used to illustrate the
point. The ORE of 99.9904% is obtained from a 133 Ib/hr
3-6
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TABLE 3-2
CALCULATION OF DRE
Step
Required Data
Computation
I. Computation of
II. Computation of Stack
Gas Sample Volume
CO
I
Designated POHC
POHC concentration
Waste feed rate
win = (Cone, of POHC)(Waste feed rate)
*m
vm(std)
where:
P + (H/13.6)
T
0.3858°K/mm Hg
17.647°R/in Hg
Volume of gas measured
by dry gas meter, cor-
rected if necessary, dscf
Y = Dry gas calibration factor
P = Barometric pressure, in. Hg
H =• Average pressure differen-
tial across sampler orifice
meter, in. ^0
Tm = Absolute average dry gas
meter temperature, °R
Note: This sample volume must include water collected during sampling and be
expressed under standard conditions (293°K, 760mm Hg; or 528°R,
29.92 in Hg). After the corrected dry gas volume has been computed, it
must be corrected for the volume of water collected during sampling:
^w(GAS) = Volume of water
vapor at standard
conditions, scf
vw(GAS)
where: K2 = 0.00133 m3/ml
= 0.0471 ft3/ml
'w
Volume of water collected
in Impingers and silica gel, ml
-------
TABLE 3-2 (Continued)
Step Required Data Computation
Note: The volume of water vapor is added to Vm/8t<|\ to obtain sample volume:
Sample volume - Vw(GAS) + VM(stdj
III. Computation of POHC Total weight of POHCs Cg - Total weight of POHC in sample
Concentration in in the sample Volume of sample at standard conditions
Stack Sample (Cg) Volume of sample at
standard conditions
IV. Computation of Stack Vg - Gas velocity, ft/min. Vg - 952C
Gas Flow Rate C - Pitot tube correction
factor (usually 0.85 for
o, Type S and 1.00 for others)
oo Pfl - Absolute pressure in flue,
in. Hg
G8 - Specific gravity of flue
gas with respect to air:
G8-M8/(28.99)
where: M8=Md[(100-W)/100]+(0.18)(W)
W "Water content of flue gas, Z
Md=(0.44)(ZC02)+(0.28)(ZCO )+(0.32)(Z02)+(0.28ZN2)
h - Velocity pressure at sampling
point (if these differ greatly
among the sampling points, the
averages of the square roots of
the velocity pressure must be
used (see ASTM D2928) in. H20
T8 - Absolute temperature of
stack gas, °R
-------
TABLE 3-2 (Concluded)
Step
Required Data
Computation
Note: The stack gas flow rate is determined by a pitot tube which measures the
difference between the total and static pressures in a flue. Gas
velocity determinations are made at several locations during sampling
and the values are averages. EPA Method 2 or ASTM Method 2928 may be
used to obtain data.
V. Computation of Wout
U)
I
VI. Computation of DRE
"8
Q -
in '
out
Stack gas volume flow
rate at standard con-
ditions, scf
cross sectional area
of stack, Ft2
POHC concentration in
stack gas
Stack gas volume flow
rate at standard
conditions
= waste in
waste out
Vg As (528/Ts)(P8/29.92)
W
out
DRE
100
in
-------
TABLE 3-3
SAMPLE CALCULATION OF DRE
10
I
Data Computation
I. Designated POHC: Hexachlorobenzene Win - .133 (1000 Ibs/hr)
POHC Concentration: 13.3Z - 133 Ibs/hr
Waste feed rate: 1000 Ibs/hr
II. Vm - 31.153 dscf vm(std)"17-64 °R (31.153d8cf)(1.12) /29.82 in.Hg+-705 in.H20
Y - 1.12 HT. Hg I 13.6
P - 29.82 in. Hg. V554°R
H - .705 in. H20 ' - 33.17 dscf
Tm - 554°R
Vw - 90.7 ml Vw(Gae) - 0.0471(90.7)
- 4.27 scf
Vw(Gas) - 4.27 scf , Sample volume - 33.17 scf + 4.27 scf
- 37.44 scf
vm(std) - 33.17 scf
III. Total weight of POHC: Cg - 4.18 x 10"5 grams
3.5 fig hexachlorobenzene extracted 37.44 scf
from water
+12.3 fig hexachlorobenzene extracted - 1.116X 10~° grams/scf
from particulate matter - 2.46 x 10~9 Ib/scf
+26.0 fig hexachlorobenzene extracted
from gas phase trap
41.8 fig - 4.18 x 10~-> grams hexachlorobenzene
Sample volume - 37.44 scf [from Step II]
-------
TABLE 3-3 (Concluded)
Data Computation
IV. C = 0.85 Vg = 952(.85) / (.202)(582) \ °-5
Ps = 29.81 in. Hg \(29.81)(0.850)
Gg = 0.850
h = 0.202 in. U20 = 1743 ft/min
T0 = 582°R
Ls
As = 55.0 ft 2 Q - 1743 ft/min (55.0 ft2)(528/582)(29.81/29.92)
Vg = 1743 ft/min (from first - 86,650 scf/min
part of Step IV)
V. Cg = 2.46 x 10~9 Ib/scf Wout - 2.46 x 10~9 Ib/scf (86,650 scf/min)(60 min/hr)
[from Step III] - 0.0128 Ib/hr
Q = 86,650 scf/min
Co
M VI. Wln = 133 Ibs/hr [from Step I] DRE -= 133 Ibs/hr - 0.0128 Ibs/hr x 100
M wout = °-0128 Ibs/hr [from Step V] 133 Ibs/hr
= 99.9904%
-------
rate and a 0.0128 Ib/hr wasteout rate. If a ORE of 99.985% is used
to solve for the allowable wasteout with 133 Ib/hr waste-j^ a
wasteout value of 0.01995 Ib/hr is obtained. A wasteout rate of
0.01995 Ib/hr is 156% of 0.0128 Ib/hr. Thus the rounding.allows
over 50% more emissions than the 99.99% ORE.
2. Errors in sampling and analysis of POHCs in stack gases are
compounded by rounding. Referring to the example above, if
sampling and analysis results were in error by 50%, the actual
emission rate of POHC would be 0.0299 Ib/hr. Thus the potential
error from rounding plus sampling and analysis errors becomes 133%.
By restricting rounding of the ORE, magnification of sampling and
analysis errors can be minimized. There may be limited
circumstances where judgement could be used in rounding, e.g.,
where three or more POHCs have been selected and only one POHC has
not achieved 99.99% ORE, rounding could be acceptable. However, if
the failure is for the most-difficult-to-burn POHC, rounding is
probably not appropriate. When used, rounding should be in accord
with best engineering judgement and practice.
3.4 Hydrogen Chloride Emissions
An incinerator destroying hazardous waste and emitting more than 4
pounds per hour (1.8 kilograms per hour) of hydrogen chloride must be
equipped with emission control equipment capable of removing 99 percent of
hydrogen chloride from the exhaust gases or of limiting hydrogen chloride
emissions to 4 pounds per hour, as required under 40 CFR 264.343(b). Waste
and stack gas sample analyses usually are conducted for the chloride (Cl~)
3-12
-------
ions. The scrubber efficiency (SE) used to determine hydrogen chloride
removal may be defined as follows, based on chloride analyses:
SE = ((Cl1n - Cl0ut)/Clin) * 100
Where: C"hn = mass feed rat? of organically bound chlorides
entering the incinerator
C^out = mass emission rate of hydrogen chloride in the
scrubber exhaust gas prior to emission to the
atmosphere
Where the term "scrubber efficiency" is used, the acid gas removal
efficiency of the entire scrubber system, including the quench, particulate
removal device, and gas absorber, is the parameter being considered. The
efficiency of indivudal scrubber units can be determined, but a high
efficiency for the total scrubber system is the fundamental desired
parameter.
Since the gases exiting the scrubber are generally cool (180°F),
sampling and analysis of this gas is comparatively easy and safe. Sampling
of the hot incinerator exhaust gases is not simple and should be avoided. To
avoid hot sampling, Cljn may be calculated from the waste feed rate and the
organically bound chlorine content of the feed. A method to compute
scrubber efficiency is presented in Table 3-4 and a sample calculation of
scrubber efficiency is presented in Table 3-5.
Clout is computed from stack monitoring data. Necessary data include:
• Volume of the stack gas sample at standard conditions
• Total chlorides (Cl~) collected during sampling
• Stack gas volume flow rate at standard conditions
3-13
-------
TABLE 3-4
CALCULATION OF SCRUBBER EFFICIENCY
Step
Required Data
Computation
CO
I
I. Compute
II. Compute Volume of Stack Gas
Sample at Standard Conditions
III. Compute Total Chlorides
in Stack Gas Sample
IV. Compute Concentration of
Chlorides (Cci) in the
Stack Gas
V. Compute Stack Gas Volume
Flow Rate
VI. Compute CLout
VII. Compute Scrubber Efficiency
Efficiency (SE)
Concentration of chlorine in feed
Waste feed rate
Clin=(Conc. of chlorine in feed)
(Waste feed rate)
Note: Chlorine content must be expressed as organically bound chloride
(Cl~), obtained from combustion methods of waste analysis.
Same as DRE calculation
A = ml of titrant for sample
N = Normality of mercuric nitrate
titrant
Vj = Volume of impinger solution
Vg = Volume of sample aliquot
rngCl" = total chlorides
Gas sample volume [from Step II of
the DRE computation]
Same as DRE calculation
Q
c.
Cl
Cl
Stack gas volume flow rate
Concentration of Cl in stack
gas
in
out
See Table 3-2 for computation
mg Cl~=35.45 ANVT
m8 Cl~7sample volume
See Table 3-2 for computation
C1out = Q
-------
TABLE 3-5
SAMPLE CALCULATION OF SCRUBBER EFFICIENCY
Data
Computation
I. [Cl~] = 25%
feed rate = 2000 Ib/hr
II. V (std)
See Table 3-3
III. A = 3.12 ml
N = .01
Vx » 40 ml
Vs = 10 ml
IV. Cl" = 9.74 x 10~6 Ib
Sample Volume » 33,17 dscf
V. See Table 3-3
VI. Q » 86,650 scf/min
[from Step IV in Table 3-1]
Ccl = 2.94 x 10~7 Ib/scf
VII. Clin =8.33 Ib/min
[Step I]
Clout = 0.0255 Ib/min
[Step VI]
Clln = (.25)(2000 Ibs/hr)
- 500 Ibs/hr
=8.33 Ib/min
33.17 dscf
mg Cl~ = 35.45(3.12)(.01)(40)
10
= 4.43
= 9,74 x 10~6 Ib
CCL = 9.74 x 10"6 Ib
33.17 dscf
- 2.94 x 10~7 Ib/scf
86,650 scf/min
Clout = (86,650 scf/min) x
(2,94 x 10 ~7 Ib/scf)
= 0.0255 Ib/min
SE = 8.33 Ib/min - 0.0255 Ib/min x 100
8.33 Ib/min
99.69%
3-15
-------
The method for computing the volume of the stack gas sample (Vm(std))
employed for the ORE calculation may be used to compute the scrubber
efficiency.
The percentage of hydrogen chloride emitted in the stack gas, or
scrubber efficiency, may not be rounded upwards. In the example presented
in Table 3-5, if the scrubber efficiency was 98.81%, the value of Clout
would be four times greater. The value of 98.81 percent may not be rounded
off to 99 percent and is not in compliance with the regulatory performance
standard.
If the scrubber efficiency is less than 99 percent when hydrogen
chloride emissions are greater than 4 Ib HCl/hr, the permit writer must
notify the applicant that the hydrogen chloride emissions exceed the
regulatory performance standard.
3.5 Particulate Emissions
Incinerators destroying hazardous wastes must not emit particulate
matter at concentrations greater than 180 milligrams of particulates per dry
standard cubic meter of stack gas (0.08 grains per dry standard cubic foot)
when the stack gas is corrected to a 7 percent oxygen concentration, using
the following formula for the correction factor specified in 40 CFR
264.343(c):
Correction Factor = 14/(21-Y)
Where: Y = measured oxygen concentration in the stack gas on a dry
basis.
The measured particulate concentration is multiplied by the correction
factor to obtain the corrected particulate emissions. A sample calculation
of particulate matter concentration in the stack gas using the method
referenced in the Sampling and Analysis Manual(3) is presented in Table 3-6.
3-16
-------
TABLE 3-6
CALCULATION OF PARTICDLATE EMISSIONS
Required Data
Computation
I. Compute Stack Gas Sample Volume
II. Determine Particulates Weight
III. Compute Particulate Matter
Concentration(P)
IV. Compute Correction Factor
V. Correct the particulate
concentration
Same as DRE calculation
Stack sampling data, weight
of collected particulates
Stack gas volume
Particulate weight
Oxygen concentration in
stack gas
P = Particulate matter
CF = Correction factor
PC = Corrected particulate
concentrations
See Step II on Table 3-2
Determined gravimetrically
P = (weight of collected particulate
matter) *• (stack gas volume)
CF = 14
21-[02]
PC = P(CF)
-------
The calculation involves the following steps:
o Determination of the stack gas sample volume
o Determination of weight of collected participate matter
o Calculation of particulate concentration in the stack gas
o Determination of the oxygen concentration in the stack gas
o Correction of the measured particulate concentration
Particulate emission calculations are sensitive to the values of oxygen
concentrations, and the permit writer may check that these values are
obtained properly. If the oxygen concentration was found to be 10.0 percent
instead of 8.0 percent in the sample calculation presented in Table 3-7, the
particulate emissions would increase to 0.081 grains per dry standard cubic
foot. Thus, the particulate emissions at 8.0 percent oxygen concentration are
in compliance with the performance standard and the emissions at 10.0
percent oxygen concentration are not. Orsat analysis for the oxygen content
of the flue gas is satisfactory and should be reported on a dry basis.
If the corrected particulate emissions are greater than 180 mg/dscm
(0.08 gr/dscf), the permit writer must notify the applicant that particulate
emissions exceed the regulatory performance standard.
3-18
-------
TABLE 3-7
SAMPLE CALCULATION OF PARTICULATE EMISSIONS
Data
Computation
I.
II.
III.
Vm(std) ' 33'17 dscf
Particulate weight =
137 milligrams
(2.113 grains)
Particulate weight =
2.113 grains
Stack gas volume =
33.17 dscf
IV. [02] - 8.0%, dry basis
V. P = 0.0637 gr/dscf
See Table 3-3
Gravimetric determination
» 2.113 grains
33.17 dscf
= 0.0637 gr/dscf
CF
14
21-8
1.077
(0.0637)(1.077)
0.0686 gr/dscf
3-19
-------
4.0 SPECIFICATION OF PERMIT CONDITIONS
The permit writer must designate a set of operating requirements
specific to each waste feed which the applicant indicates will be burned.
These requirements must reflect the set of conditions which have been shown
to achieve the performance standards of 40 CFR 264.343, either during a trial
burn conducted in the unit for which the permit is sought, or by data
submitted in lieu of conducting a trial burn. At a minimum, the permit must
specify requirements for the carbon monoxide level in the stack gas, thermal
input rate, combustion temperature, combustion gas flow rate, and acceptable
variations in the waste feed composition (40 CFR 122.27(b)(vi)). In
addition, the permit writer may include other operating requirement as
necessary to ensure compliance with the performance standards. These may
include, for example, conditions which may derive from trial burn results for
specific combinations of wastes or alternate operating conditions to be used
under specifically defined circumstances. Guidance for specifying each of
these requirements is provided in Sections 4.1 and 4.2.
The permit must also include a schedule for conducting periodic facility
inspections. Two types of inspections are required. The first, a visual
inspection of the incinerator, must be conducted daily. The second type of
inspection, testing of the emergency waste feed cut off system, should occur
at weekly to monthly intervals. Guidance for determining the best means of
testing the system and the frequency at which testing should occur is
presented in Section 4.3.
4-1
-------
Initially, the operating requirements for new incinerators will be
established on the basis of the incinerator's anticipated performance
capabilities. The requirements will be designated primarily on the basis of
the design specifications provided with the permit application and experience
or information gained from trial burns at other facilities. These
requirements will then be modified when data from the trial burn is complete
and evaluation of actual incinerator performance can occur. Further guidance
regarding the specification of operating requirements from design data is
presented in Section 4.4.
4.1 Specification of Operating Requirements From Performance Data
An incinerator permit must specify a set of operating requirements for
the following parameters:
• Carbon monoxide level in the stack exhaust gas
• Waste feed rate
• Combustion temperature
• Combustion gas flow rate.
The numerical values of those parameters will be governed by the performance
data reported by the applicant. The trial burn (or alternative) data should
include values for these operating parameters which correspond to the
performance level achieved in the trial burn. Therefore, at a minimum, a set
4-2
-------
of values for carbon monoxide in the stack gas, waste feed rate or thermal
input rate, combustion temperature and combustion gas flow rate should be
reported for a corresponding destruction and removal efficiency, mass
emissions of HC1 and/or scrubber removal efficiency, and emissions of
particulate material.
The applicant should report values for each operating parameter which
include information regarding normal fluctuations. The permit requirements
can be written to incorporate the range identified. This may be accomplished
in several ways. For example, the operating parameter values may be reported
as a range (e.g., 1800 + 50°F), or the applicant may provide the actual
readout from the monitoring instrument which shows fluctuations over time.
Submission of readouts from continuously monitoring instrumentation is
recommended. Examples of interpretation of such data is provided in Chapter
5.
The maximum amount of information can be generated by testing each of
the operating parameters at several levels during the trial burn. If each
level is reported along with a description of the fluctuation that occurred,
the applicant will have established a wide range of conditions over which
adequate performance is achieved. Permit conditions for each parameter may be
expressed as the ranges tested successfully during the trial burn. This
approach provides the operator with a high degree of flexibility during
routine operation.
4-3
-------
4.1.1 Carbon Monoxide Level In The Stack Gas
The amount of CO present in combustion exhaust gas is a function of many
factors, including combustion temperatures, residence time of the combustion
gases at the combustion temperature, degree of mixing of fuel(s) and air, and
the amount of air used in excess of stoichiometric requirements. These
factors are interdependent to some extent; however, residence time and the
degree of mixing of air and fuel(s) are primarily determined by the
combustion chamber and burner design. Therefore, changes of CO concentration
will reflect changes in excess air usage and in combustion temperatures.
The continuous measurement of carbon monoxide (CO) in the stack gas is
useful for several reasons. CO concentration is a reliable indicator of
combustion upset and remains a good indicator as excess air is lowered toward
stoichiometric conditions and as combustion temperature is lowered.
Additionally, carbon monoxide and carbon dioxide concentrations can be used
to determine combustion efficiency.
Monitoring CO in the exhaust gas is most conveniently done in the
exhaust stack, where temperatures are low. However, measurement of CO at
other points in the system is acceptable. For example, CO may be measured in
the take-off ducting immediately after the combustion chamber or after-
burner.
The permit writer should specify, as the maximum allowable CO
concentration, the maximum CO concentration reported from the trial burn
4-4
-------
demonstrating compliance with the performance standards. However, some
allowance for normal variation may be specified in the permit in order to
protect against unnecessary activation of the waste feed cutoff system.
Following the trial burn, the applicant should submit the actual readout from
the CO monitoring device. This chart will provide data describing the average
CO concentration and the frequency, magnitude and duration of any downward or
upward spikes. Permit conditions that accomodate some degree of fluctuation
in the stack gas CO concentration can then be selected on the basis of this
information.
4.1.2 Waste Feed Rate
The waste feed rate may be effectively controlled by stipulating the
maximum total thermal input rate to the incinerator. The permit writer is
encouraged to specify the maximum total thermal input rate (e.g., Btu per
hour) including the heating values contributed by hazardous waste, non-
hazardous waste and auxiliary fuel, in all permits. In conjunction with
specifying the minimum heating value of the waste feed, control of the
thermal input rate will ensure that the incinerator is not overloaded with
difficult to incinerate hazardous constituents and that compliance with the
performance standards is maintained. Because the total thermal input is
derived from trial burn data, the applicant gains greater flexibility in a
permit by operating at the maximum thermal input that at a lesser thermal
input during a trial burn. Turndown, or reduced thermal input to an
incinerator, from the maximum permitted value is allowable if compliance with
the other permitted operating conditions is maintained. Additional restrictions
4-5
-------
on the waste feed rate may be imposed by specifying a mass or volume feed
rate of the waste (e.g., pounds per hour, gallons per hour).
Some incinerators have multiple waste feed locations. The permit writer
may include restrictions on wastes fed at certain locations to insure a
minimum residence time in the incinerator. Similar restrictions may be
placed on the quantity of wastes containing very toxic constituents that may
be fed to an incinerator.
The following example illustrates specification of both the total
thermal input and a mass feed rate.
Tetrachloroethylene is the most difficult POHC to incinerate present in
Waste A. Waste A is successfully incinerated during a trial burn at a feed
rate of 100 Ib/hr, using 100 Ib/hr of auxiliary fuel. If the heating value
of Waste A is 5000 Btu/lb and that of the auxiliary fuel is 18,000 Btu/lb,
the total thermal input is 2.3 million Btu/hr. The permit may be written
specifying the maximum feed rate and minimum heating value of Waste A, and
the maximum allowable total thermal input, 2.3 million Btu/hr for more easily
incinerated wastes. Thus, Waste B, having heating value of 10,000 Btu/lb and
all hazardous constituents easier to incinerate than tetrachloroethylene, may
be fed to the incinerator at rates up to 230 Ib/hr if no auxilliary fuel is
burned. Alternatively, the incinerator can be operated co-burning 100 Ib/hr
of Waste A and 180 Ib/hr of Waste B to achieve the maximum thermal input of
2.3 million Btu/hr. The net effect of specifying the total thermal input is
to permit the substitution of easily incinerated waste for auxilliary fuel if
specified operating conditions, such as combustion zone temperature and air
feed rate, are maintained. Additional examples of specifying the total
thermal input are provided in Chapter 5.
4-6
-------
Specification of waste feed as mass feed rate of the POHCs will
generally not be necessary. Such a permit condition would require frequent
analysis of incoming wastes and feed tank blends in order to ensure permit
compliance. The permit limitations on other operating parameters fix the
temperature, residence time and heating value of the waste, reducing the need
for feed rate stipulations based on mass input of the POHCs.
Waste compositions are specified in a permit for each waste or waste mix
having a different physical state. The permit writer has the option of
developing permit conditions for wastes with the same physical state,
entering the incinerator at the same location, as separate wastes or as a
single waste mix. The physical states of wastes in the form they enter the
incinerator are classified as pumpable liquids, non-pumpable or solid
materials, and containerized wastes. Pumpable liquids include pumpable
slurries and highly aqueous wastes. Non-pumpable wastes include sludges,
tars, and solid materials having high ash contents. The definition of wastes
having different physical states as separate wastes in a permit is necessary
to ensure adequate volatilization of the hazardous constituents from a waste
prior to flame oxidation. For example, the volatilization of hexa-
chlorobenzene from a liquid solvent atomized in a burner is much faster than
the volatilization of hexachlorobenzene from a still bottom tar. Accordingly,
the maximum mass loading rate that may be incinerated in compliance with the
performance standards of the liquid waste is likely to be much greater than
that of the sludge and the permit must take these factors into account.
Waste feed locations are specified in a permit in order to ensure
adequate retention time in the combustion chamber. Waste feed locations
upstream of those used during a satisfactory performance test provide
4-7
-------
additional residence time in the combustion chamber and generally are permissable.
Downstream feed locations may decrease effective residence time and should
not be permitted because the ORE may be lowered out of compliance.
Wastes having the same physical state fed to the incinerator at the same
location may be regarded as one waste in a permit. The permit writer has the
option to consider such wastes a waste mix and specify the mixed waste
composition in a permit. Alternatively, the composition of each waste stream
may be specified in the permit. The applicant may prefer one of the options
and the permit writer should prepare the draft permit accordingly.
The specification of wastes of different physical form and multiple feed
locations is illustrated using the example in Figure 4-1. Assuming that all
the performance test results are in compliance, wastes C and D must be
defined in the permit separately because the physical states are not the
same. The incinerator charging rate may be specified on the basis of total
thermal input, or the combination of thermal input and mass input rates. If
mass loading rate is used, the permit would specify that 600 Ib/hr of waste C
having a minimum heating value of 7000 Btu/lb and a maximum organically bound
chlorine content of 6 percent may be fed to the kiln. 600 Ib/hr of waste D
having a minimum heating value of 8000 Btu/lb and a maximum organically bound
chlorine content of 10 percent may be fed to the kiln. Specifying the total
thermal input, no more than 4.2 million Btu/hr of waste C and no more
4-8
-------
A — »
B — *
c -3
D —)
Kiln
A — »
Afterburner
Waste Feed Locations
Waste
Waste
i
vO
Physical State
Physical State
Liquid
B
C
D
Liquid
Solid
Drummed
Waste Characteristics
Feed Rate
(Ib/hr)
400 to afterburner
600 to kiln
500
600
600
Heating Value
(Btu/lb)
10,000
2,000
7,000
8,000
Organically Bound
Chloride Content (%)
15
3
6
10
FIGURE 4-1
EXAMPLE OF MULTIPLE WASTE FEEDS TO A ROTARY KILN INCINERATOR
-------
than 4.8 minion Btu/hr of waste D may be fed to the incinerator. Wastes C
and D must be fed to the kiln and may not be fed to the afterburner in order
to ensure sufficient residence time.
Wastes A and B have the same physical state and both are fed to the
kiln. Only Waste A is fed to the afterburner. The waste composition may be
specified in a number of ways. Wastes A and B may be considered a waste mix
entering the kiln (see the example above) and the total allowable waste fed
to the kiln includes the amount of waste A fed to the afterburner. Waste B
may not be fed to the after-burner. The permit would specify that 1500 Ib/hr
of liquid waste having a minimum heating value of 7400 Btu/lb, and for no
more than 11.1 million Btu/hr of liquid waste, having a maximum organically
bound chloride content of 11 percent may be fed to the kiln. Another option
is that Wastes A and B may be considered a waste mix to the kiln and may
include Waste A to the afterburner, if operating conditions for the
afterburner are stipulated separately. Weighted averages may be used to
establish the heating value and chloride content. The permit would also
specify that 400 Ib/hr of waste A may be fed to the afterburner with a
minimum heating value of 10,000 Btu/lb and a maximum organically bound
chloride content of 15 percent.
The other method to develop the permit is to define wastes A and B
separately at each feed location, using mass feed rate or total thermal
input. Using the mass feed rate for example, 400 Ib/hr or waste A can be fed
to the afterburner, 600 Ib/hr or waste A can be fed to the kiln, and 500
4-10
-------
Ib/hr of waste B can be fed only to the kiln. Waste A must have a minimum
heating value of 10,000 Btu/lb and a maximum organically bound chloride
content of 15 percent. Waste B must have a minimum heating value of 2000
Btu/lb and a maximum organically bound chloride content of 3 percent.
4.1.3 Combustion Temperature
The permit needs to specify a minimum allowable combustion temperature.
This value should be the minimum temperature shown during the trial burn,
or by alternative data, to correspond with achievement of the required
performance standards. Specification of a maximum allowable combustion
temperature is not necessary because increased temperatures presumably
increase destruction efficiency. Furthermore, the maximum temperature at
which the incinerator will be operated is limited by refractory capabilities
and other design considerations.
In setting the requirement for minimum allowable combustion temperature,
the permit writer should consider temperature fluctuations encountered during
the performance test. The heated refractory will act to maintain thermal
stability and temperature fluctuations should not be great. However, some
allowance for normal variations is needed in order to protect against
unnecessary activation of the waste feed cutoff system as a result of
temperature "spiking" (see Section 4.1.5). Examples of the specification of
minimum permitted operating temperature are provided in Chapter 5.
4-11
-------
Consideration must also be given to the location of the temperature
sensing device. In many instances, temperature sensors will be located at
several points in the system. The reported temperature should be measured at
the point where the data will be most representative of the gas temperature
as it exits in the combustion chamber. Although the exact location of the
temperature sensor will vary in each case, a location should be specified in
the permit in order to ensure that temperature is always monitored at the
same point in the system during routine operation.
4.1.4 Combustion Gas Flow Rate
Combustion gas velocity is an indicator of the flue gas volume flow
rate, which is a function of thermal input to the incinerator, gas
temperature, and excess air usage. Measurement of combustion gas flow rate
provides a good indication of residence time in the combustion zone.
The maximum combustion gas velocity (or exit gas velocity) shown during
the trial burn (or by alternative data) as corresponding to achievement of
the required level of performance should be designated as the maximum
allowable velocity. Specification of a minimum velocity is not necessary
since the required performance should be maintained at turndown provided that
all other operating parameters are maintained. The permit writer should
recognize that incinerators burning containerized wastes may exhibit sharp
momentary increases in combustion gas velocity ("puffing") upon charging.
Such variations should be incorporated into the permit conditions if
sufficient performance data are supplied.
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Combustion gas flow rate may be measured by many different means.
Combustion gas velocities may be measured using orifice plates or veturis,
pitot tubes, or by indirect means. Orifice plates and Venturis are
impractical for combustion gas velocity measurements because of the large
pressure drops caused by these devices. Pitot tubes may be used to measure
combustion gas velocity in the hot zone of an incinerator immediately
downstream of the combustion chamber or in cooler areas, such as the stack.
Pitot tube measurements can be converted to combustion gas velocity and
volume flow rate using the procedure in EPA Method 2 presented in the
Appendix of 40 CFR 60. Changes in the molecular weight and the water content
of the combustion gas will affect the correlation of pitot tube measurements
and combustion gas velocity.
Indirect measurements of combustion gas velocity may include blower
rotational speed and current draw. Many blowers operate in the region of the
blower curve where static pressure and current draw (horsepower) do not
change radically with a change in capacity. Therefore, blower static
pressure and current measurements are generally not suitable indicators of
combustion gas velocity unless the applicant can demonstrate a reliable
correlation. Blower rpm is indicative of combustion gas velocity and volume
flow rate only if static pressure in the blower remains constant. Measure-
ment of combustion gas velocities using blower characteristics on
incinerators equipped with more than one blower may become very complex, and
the problems may be alleviated by use of a pitot tube method instead.
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Measurement of pressure differentials across incinerator components,
such as combustion chambers and air pollution control devices, is not a
suitable indicator of combustion gas velocities. Pressure differentials may
be affected by leakage, changes in liquid flow rates, and clogging phenomena
as well as gas flow rates. It is not usually possible to distinguish the
factors affecting changes in pressure measurements using conventional
equipment. Therefore, pressure differential measurements should not be used
as gas velocity indicators; however, they may be useful monitors for upset
conditions.
Continuous monitoring of the oxygen concentration in the stack gas is an
acceptable substitute for combustion gas velocity measurement. The oxygen
concentration is indicative of excess air usage and, if waste feed
composition and feed rate remain constant, it is an indirect measurement of
the combustion gas volume flow rate. The most common method of continous
oxygen measurement is an electro-catalytic device, and paramagnetic and
polarographic instruments are used. The monitors are either in-situ or
extractive. Additional information about instrument capabilities is presented
in the Engineering Handbook.
4.1.5 The Emergency Waste Feed Cutoff System
The purpose of the automatic waste feed cutoff system is to shut off
waste feed to the incinerator whenever the operating parameters deviate from
the limits set in the permit. For this reason, the cutoff valve should be
interlocked to all of the required continuous monitoring devices. These
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devices include monitors of temperature, combustion gas velocity, and carbon
monoxide level in the stack gas. For each of these parameters, the permit
should include a provision that establishes both a range for operation and a
level, somewhat beyond that range, at which the emergency waste feed cutoff
system must be activated. The following discussion provides an example for
proper integration of the waste feed cutoff system with the combustion
temperature monitor. Similar approaches may be taken for integration with
other operating parameters as well.
Following the trial burn, the applicant should submit the actual readout
from the temperature recording device. This chart will provide the permit
writer with data describing the average operating temperature and the
frequency, magnitude and duration of any downward or upward spikes. Effective
permit conditions can be selected on the basis of these data. Generally, the
permit will specify that the incinerator be operated at or above the average
temperature tested during the trial burn. Additionally, the permit should
specify that the automatic waste feed cutoff be activated at a lower
temperature than the range of normal fluctuation indicated by the results of
the trial burn.
This cutoff temperature may be selected in several ways, each of which
requires some degree of judgment. The automatic cutoff temperature may be
selected by calculating a time-weighted average of the temperatures recorded
below the target operating temperature. Alternatively, the permit writer may
select the temperature of the lowest spike as the automatic cutoff
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temperature. In this case, however, a rarely occurring, very large downward
spike should be considered unrepresentative of normal temperature fluctuation
and should be disregarded. The permit condition might also be written to
establish an automatic cutoff which allows for momentary excursions by
specification of allowable excursion magnitude, frequency and duration.
Conceptually, this type of control could best be accomplished using a system
which would limit the total number of degree-minutes below a prescribed level
before activation of the waste feed cutoff mechanism. Such a system,
however, will not always be available for use by the operator. The necessary
limits for such a system would vary from case to case. The permit writer
should require that detailed information regarding temperature fluctuations
be provided. When selecting the actual limit on degree-minutes of deviation,
the permit writer should generally allow deviations to occur for only a small
fraction of the total operating time. This approach is advantageous because
it allows for the possibility of very large, but infrequent and brief
downward spikes without activation of the automatic waste feed cutoff. This
concept is illustrated in Section 5.1.2.
4.2 Limitations On Waste Feed Composition
Permit limitations on waste feed composition should address two aspects
of the waste: allowable waste constituents and chemical and physical waste
characteristics. The actual limitations selected for these parameters depends
on the results of the trial burn. Permit conditions regarding allowable waste
constituents are restricted to limitations on those substances listed as
hazardous constituents in Appendix VIII of 40 CFR Part 261.
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Limitations on the physical and chemical characteristics of the waste
feed may be used, rather than stipulations on allowable POHC concentrations.
Theoretically, incinerator ORE performance is independent of POHC
concentration, provided that limitations are placed on the other physical and
chemical characteristics of the waste and on the incinerator operating
parameters. However, in practice, this approach will be most reliable if the
trial burn is conducted using the largest POHC concentrations anticipated
during normal operation. Guidance for selecting limitations on chemical and
physical characteristics is presented in this section.
The method described for restricting waste feed composition has been
designed to minimize the burden of time consuming and complex chemical
analysis. This is accomplished by using operating requirements and
restrictions on physical and chemical characteristics of the waste to ensure
adequate performance.
4.2.1 Allowable Waste Feed Constituents
The number and identity of allowable hazardous waste constituents
specifed in the permit will depend primarily on the waste constituents burned
during the trial burn and on their placement on the hierarchy of
incinerability (presented in Chapter 2). The principle which should govern
writing the permit is that allowable hazardous constituents are those which
exhibit higher heat of combustion values (i.e., those which are easier to
burn) than the POHCs for which the required performance was shown either in a
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trial burn or by alternative data. In this way, the determination of
allowable hazardous constituents can be derived directly from the hierarchy of
incinerability.
In practice, this approach allows the applicant to control the number of
hazardous constituents which the permit will allow him to burn (and hence,
the range of wastes which can be accepted for treatment at the facility)
through careful design of the trial burn. If a wide range of flexibility is
needed, the trial burn should be conducted using a waste containing
significant levels of POHCs having very low heat of combustion values. The
permit would allow burning of wastes containing constituents which are easier
to incinerate if compliance with the performance standards is demonstrated.
After successful completion of a trial burn, it is not necessary that
the permit writer automatically allow burning of all constituents, without
regard to their concentration in the waste, which fall below the trial POHCs
on the hierarchy. The permit writer may deem certain exclusions or
restrictions on concentration necessary. Such restrictions should be
considered in cases where a substance known or suspected to be a highly
potent human toxicant (e.g., 2,3,7,8-TCDD) falls below the trial POHC on the
hierarchy.
In order to maximize flexibility of the permit conditions regarding
allowable waste feeds, the applicant may burn a contrived waste during the
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trial burn which has been spiked with one or several POHCs known to be
difficult to destroy. In such a case, the applicant will gain flexibility in
terms of allowable hazardous constituents (and, therefore, waste feeds).
However, since compliance is established at conditions sufficient to destroy
the most difficult POHC to incinerate, the permit will require that all
wastes be treated under these same conditions.^
In cases where a contrived waste is used during the trial burn, the
permit writer should also consider concentration of the POHCs in the trial
waste. The contrived waste should contain POHCs in concentrations which are
representative of concentrations expected to be found in the actual wastes
managed at the facility. Spiking the trial waste with POHCs in concentrations
which are somewhat higher or in the upper range of concentrations expected to
be encountered during routine operation will provide greater assurance that
the operating requirements will be sufficient to achieve compliance with the
performance standards. In all such cases, very large differences between the
trial POHC concentrations and the expected waste concentrations should be
avoided, and the concentration of POHCs in the trial burn waste should always
be greater than or equal to the POHC concentrations expected during routine
operation.
As described in Chapter 2, this situation may be avoided if the applicant
groups the wastes according to incinerability and establishes a set of
operating conditions for each group of wastes. In such a case, a trial
burn would be necessary to show the required performance for the most
difficult to destroy POHC(s) from each waste group.
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4.2.2 Limitations On Chemical And Physical Waste Feed Characteristics
In addition to specification of allowable waste constituents, the permit
should set appropriate limits on the chemical and physical properties of the
permitted waste(s). The parameters for which limits should be set include,
at a minimum:
• Heating value
• Ash content
t Organically bound chloride content
• Physical characteristics (e.g., physical state).
These limitations, together with the operating requirements discussed in
previous sections (in particular, stipulations on waste feed rate), limit
operations to such an extent that the performance level demonstrated during
the trial burn should be achieved and maintained during routine operation.
4.2.2.1 Heating Value
Knowledge of the waste feed heating value is necessary to maintain a
relatively constant thermal load to the incinerator thereby resulting in
stable combustion zone conditions. Gross decreases in the heating value of
liquid and gas feed streams may indicate major changes in the concentration
of hazardous constituents, which would make the waste more difficult to
incinerate. Additionally, a permit condition for waste heating value may be
used to convert the waste feed rate from units of mass per unit time to Btu's
per unit time. Stipulation of waste feed rate in this manner will be
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advantageous in cases where the operator normally controls heat content of
the waste feed in order to maintain stable combustion conditions. The lowest
heating value for liquids and gases shown to correspond with the required
performance level, either during a trial burn or by alternative data, should
be designated in the permit as the lowest allowable heating value.
A lower limit will also encourage blending of liquid waste feeds which
contributes to steady, consistent operation of the incinerator. An upper
limit on heating value of liquids and gases is not necessary because wastes
with higher heating values are presumably more easily burned.
When waste streams to be burned cannot be adequately blended as in the
case with high water content wastes and many organic wastes, blending to meet
a lower permit limit becomes impractical. Since these wastes, if mixed,
would form separate phases and introduce undesirable upsets in heat release,
it becomes necessary to inject "water" wastes separately. In this situation
a minimum heating value on a stream consisting primarily of water would be of
little value, but the Btu value of the separate streams when averaged
together should still meet a specified limit. The permit writer, when
evaluating the separate injection of water waste, must be aware of the
potential for flame quenching of the higher heating value waste. In
approving the trial burn plan and developing final permit conditions, the
permit writer must exercise caution to avoid flame quenching situations or be
aware of their impact. Careful design of the trial burn conditions to
reflect the worst case situation is the key to avoiding or minimizing
problems of flame quenching.
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However, in the case of solids fed to rotary kilns, hearths and other
solids handling incineration equipment, a different approach to specifying a
heating value for waste is needed. Many solid wastes, by their very nature,
are subject to wide variations in heating value, and rotary kiln, hearth, and
similiar incinerator designs attempt to deal with this problem. Such designs
provide for the volatiles in the solids to be vaporized and subsequently
destroyed in an afterburner or secondary combustion chamber. Thus in
specifying heating values for solid waste feeds, a lower heating value limit
may not be required if the incinerator is equipped and operated to maintain
sufficient temperature by addition of liquid waste or auxiliary fuel.
The permit writer, in evaluating incinerators handling solids, should be
aware of a different problem related to the heating value of solids. Many
solids, including drummed materials, can cause sudden increases in heat
release in an incinerator. Such sudden increases can result in
overpressuring in negative pressure systems (puffing) and oxygen deficient
combustion conditions. This results in fugitive emissions and incompletely
combusted materials in the stack effluents. In setting heating value limits
for solids fed, the permit writer may consider placing an upper limit on the
quantity of waste in each drum on a mass or Btu basis and/or limiting the
rate at which solids and drums can be charged to the incinerator.
4.2.2.2 Ash Content
Specification of the maximum allowable ash content will, to some extent,
ensure that the particulate removal capability of the air pollution control
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system is not exceeded during normal operation. Only a maximum allowable
level need be specified. Because ash content and exhaust gas particulate
load do not correlate directly, this permit condition is not intended as a
direct means of controlling particulate emissions. Rather, it is intended to
provide an indication that, with respect to ash content, the waste feed to
the incinerator remains similar to that tested during the trial burn.
Specification of an effective permit condition for ash content will be
particularly difficult when the trial burn waste is contrived by blending
wastes or chemicals. In such cases, the contrived blend should contain a
material (such as fly ash) suitable for simulating a particulate load that
is equal to or greater than that expected during routine operation. Several
factors should be considered when selecting an appropriate material for this
purpose. They include particle size distribution, mean particle diameter,
the resistivity of the material, the degree to which it may react with the
stack gas (and influence the ORE), and the design of the particulate
collection device. The waste feed selected for use in the trial burn should
contain ash at levels similar to or higher than those expected during normal
operation.
4.2.2.3 Organically Bound Chloride Content
The organically bound chloride content of a waste may be correlated with
scrubber performance. In order to avoid overloading the scrubber and
possibly exceeding the hydrogen chloride emission standard, the maximum
allowable organically bound chloride concentration should be that for which
compliance with the performance standard has been demonstrated. Lower
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organically bound chloride concentrations in the waste are allowable
variations.
4.2.2.4 Physical Characteristics
Changes in the physical state of the waste feed can result in changes in
incinerator performance. The permit should therefore limit the physical
state of the waste to that of the trial burn waste. Precise guidance for
establishing limits on physical characteristics is not provided because
determinations will be highly case-specific and will require application of
engineering judgement. The following discussion provides a specific example
which might be used for comparative purposes.
An incinerator having both liquid injection and rotary kiln capabilities
may effectively treat liquid, solid and sludge wastes. Furthermore, any of
these wastes might be fed to the incinerator in containers. The trial burn
should be conducted such that the POHCs are introduced in the physical form
in which they are likely to be received during routine operation. The permit
should then restrict the allowable physical form to that used during the
trial burn.
If containerized hazardous wastes are to be burned, the permit writer
should consider the need to limit the condition or construction of the drums
as they enter the combustion zone. For example, when closed steel drums are
fed to a rotary kiln incinerator, explosion of the drums inside the kiln may
result in "puffing", or release of highly concentrated emissions from the
kiln. The permit, therefore, might specify that drums be opened or punctured
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immediately prior to charging in order to minimize puffing. However, if the
trial burn demonstrates that introduction of closed drums does not result in
puffing, the requirement that drums be opened may not be necessary.
4.3 Specification Of Inspection Requirements For The Emergency Waste Feed
Cutoff System
The incinerator regulations require weekly testing of the automatic
waste feed cutoff system. Monthly testing may be allowed in cases where the
applicant has shown that weekly testing will be highly disruptive and that
monthly inspection is sufficient. This test is intended only to verify
operability of the emergency waste feed cutoff system and should not require
dismantling of equipment or unscheduled calibration of sensors.
Complete shutdown of the incinerator is not necessary for testing the
feed cutoff valves or devices and the associated safety system. The valves
may be checked while waste is input to the incinerator and the potential for
creating upset conditions are at a minimum. The valve needs to be activated
only once during an inspection; a check of every input to the safety system
does not have to activate the valve. Additionally, if the valve is "fail
safe" (i.e., it fails in the closed position), only the control panel
circuits and associated alarms need weekly testing; the valve need not be
activated. Since cut off valves are designed to operate for over one million
cycles, testing should not be considered to contribute significantly to wear.
Detectors and sensors are generally connected to the cut off valve through
relays, which are often equipped with an integrated test circuit.
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The permit writer should specify the inspection requirements on a case-
by-case basis. Although safety system design is fairly standard due to
insurance requirements, the following factors should be taken into account
before specifications of a schedule for testing:
• Extent of integration of the incinerator with other on-site
processes. If the incinerator is closely integrated, testing is
likely to be complex and time consuming.
• Installation of multiple burners. Incinerators with more than one
liquid waste burner will be better able to maintain thermal input
to an incinerator as the cutoff value to each burner are tested.
• Presence of a solid waste loading system. Momentary cut off during
inspection of a conveyor belt, screw feeder, or hydraulic ram
should not upset incinerator conditions because such feed systems
are not likely to be the only source of thermal input.
• Availaibility of test circuits. Checks and inspections of safety
systems equipped with test circuits, test jacks, and signal
simulators are easily performed and may not require the presence of
an instrument mechanic.
• Safety system design. The more complex a safety system is, the
longer it will take to check. Also, if accessability to system
components is a problem, a system check is further complicated.
When evaluation of these factors indicates that weekly inspection may be
impractical, alternatives may be considered. For example, weekly inspection
might be limited to testing the waste feed cutoff valve and more
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comprehensive testing of the system (e.g., verifying operability of alarms,
sensors and associated control circuitry) could be conducted at longer
intervals. Such a minimum weekly inspection could involve triggering of the
waste feed cutoff valve by a simulated low combustion chamber temperature.
This test should be conducted by properly trained personnel, e.g., an
instrument mechanic. Should the test reveal that the system is not
functioning properly, the permit should require that the waste feed be cutoff
immediately and the necessary repairs made.
A second approach to inspection of the waste feed cutoff system might
involve weekly testing of the valve and rotational testing of the control
circuitry which interlocks the valve with the various control parameter
monitors. For example, during Week 1, the valve might be activated by
inducing a low temperature condition. During Week 2, a high carbon monoxide
level might be used to activate the valve. This would be followed, in Weeks
3 and 4, by activation of the circuitry interlocked to the gas flow velocity
monitor and any other continuous monitoring devices. This inspection method
incorporates weekly testing of the cutoff valve(s) with rotational (monthly,
or bimonthly) testing of the system components.
Daily incinerator inspection may be limited to visual examination for
leakage, spills, corrosion, hot spots and malfunctions. The inspection should
reveal whether gauges, recorders, and monitors are functioning and if there
are any signs of tampering with incinerator equipment. Visual inspection
should also identify needs for repair.
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5/0 EXAMPLES OF SPECIFICATION OF PERMIT CONDITIONS
The examples of the specification of permit conditions provided in
this chapter are intended to illustrate some of the approaches to per-
mitting discussed in this manual.
Example 1; The first example demonstrates the development of permit
conditions for an on-site incinerator dedicated to burning one hazardous
waste under one set of operating conditions. This permitting situation is
straightforward and is used to illustrate the development of permit
conditions from performance results and the interpretation of engineering
data.
Example 2: The second example illustrates the permitting of a hearth
incinerator burning a solid waste and a liquid waste at one set of
operating conditions. The purpose of this example is to demonstrate how a
permit is written to allow the incineration of more than one hazardous
waste and how the maximum thermal input is used to limit waste feed rates.
Example 3: In the third example, two hazardous liquid wastes are co-
incinerated with a solid waste mixture and the incinerator operating
conditions depend on which liquid wastes are being co-incinerated. The
third example illustrates the permitting of incineration of specific
hazardous wastes at specific operating conditions and the use of the waste
grouping concept.
The examples in this chapter address the specification of waste composi-
tion and incinerator operating conditions from selected data appearing in a Part
B application and do not include the specification of other provisions that
must be included in a permit, such as monitoring, safety, and inspection
requirements. Each example in this chapter is summarized in two tables; one
table contains the trial burn data that comprise part of the permit application
and the other table lists the permit conditions developed from these data. The
combustion zone temperature is used as a surrogate for all continuously
monitored operating parameters such as combustion gas velocity and carbon
monoxide concentration in the stack gas. The final permit must specify each of
these parameters. It is assumed that all numerical values have been checked and
found acceptable.
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5.1 Discussion of Example 1
5.1.1 Case Description
Sample permit application data are listed in Table 5-1. The incinerator is
a single chamber liquid injection unit integrated with a production process.
The waste stream to be incinerated is fairly consistent in terms of waste
quantity and composition. The heating value ranges from 8000 to 10,000 Btu/lb,
and the applicant used a waste sample with 8000 Btu/lb for the trial burn. Of
roughly a dozen Appendix VIII constituents that were present based on waste
analysis data submitted with the permit application, three POHCs were selected
for the trial burn: dioxane (heat of combustion 6.41 kcal/gm); ethylene oxide
(heat of combustion 6.86 kcal/gm); and phenol (heat of combustion 7.78
kcal/gm). The concentrations of these POHCs in the waste were the following:
dioxane 3%; ethylene oxide 5%; phenol 20%. The applicant indicated that
concentrations of each constituent varied not more than +25% from these values.
The waste analysis showed chloride content and ash content of 0.5$ and 0.8%
respectively. For the trial burns the applicant proposed two operating
conditions, one targeted at 2100°F, the other at 2300°F.
The applicant could have built additional flexibility into his permit by
extending his trial burn to include waste having lower heating value, higher ash
or chlorine content, or additional POHCs more difficult to incinerate than
dioxane.
5.1.2 Development of Permit Conditions
The results of the trial burn are shown in Table 5-1. The trial burn at
2100°F achieved 99.99% ORE only for phenol. The trial burn at 2300°F achieved
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TABLE 5-1
SAMPLE PERMIT APPLICATION DATA - EXAMPLE 1
Incinerator: Single Chamber Liquid Injection
Waste Characterization Data
Waste 1
Physical State Liquid
Heating Value 8,000-10,000 Btu/lb
Organically-Bound Chloride <0.5%
Content
Ash Content <0.8%
POHCs Dioxane
Ethylene oxide
Phenol
Two trial burns were conducted generating the following data:
Incinerator Operating "Conditions
Test 1 Test 2
Waste Feed Rate - Waste 1 600 Ib/hr 600 Ib/hr
Combustion Chamber Temperature
Primary See Figure 5-1
Secondary
Waste Feed Location Primary Primary
Trial Burn Results
DRE - Dioxane 99.97% 99.99%
Ethylene oxide 99.984% 99.992%
Phenol 99.991% 99.995%
Particulate Emissions* 0.075 gr/dscf 0.068 gr/dscf
HC1 Emissions <4 Ib/hr <4 Ib/hr
* at 50% excess air
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99.99% ORE for all three POHCs. The participate and HC1 emissions were in
compliance in both trial burns. The resulting permit conditions are shown in
Table 5-2. (Note: Limits on air feed rate and CO in the stack gas are not shown
in this example, but they would be derived directly from trial burn conditions.)
The derivation of the permitting operating temperatures from the con-
tinuously recorded combustion zone temperature is very important in this
example. Samples of the recorded temperatures from each performance test are
presented in Figure 5-1. The mean temperature during Test 1 was 2160°F based
on temperatures measured at 15-minute intervals. Because there were three
temperature spikes which lasted over 45 minutes of this 7-hour performance test,
a mean value obtained at less frequent intervals might be skewed. Ideally, the
mean temperature should be obtained from measurements at more frequent
intervals. Although the temperature increased approximately 200°F during the
trial burn, the amount represents an increase of less than 10 percent. The
temperature spikes account for approximately 10 percent of the time of the
performance test. Considering both of these values, the incinerator is
probably operating at steady state conditions. If the values were considerably
less than 10 percent deviations, steady state conditions would definitely
exist. If the deviations were greater than 15 percent, the incinerator would
probably not be operating at steady state.
Specification of the allowable temperature range for Test 1 is difficult.
The standard deviation of the Test 1 temperatures at 15 minute intervals is
121°F. The standard deviation might be used to establish the allowable
temperature range; however, the deviation increases as the incinerator
approaches non-steady state conditions, which should not be permitted. If the
incinerator operates at ideal steady state conditions, use of the standard
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TABLE 5-2
SAMPLE PERMIT CONDITIONS - EXAMPLE 1
• The permittee is allowed to burn liquid hazardous wastes with the
following composition:
- Minimum heating value is 8,000 Btu/lb
- Maximum organically bound chloride content is 0.5%
- Maximum ash content is 0.8%
- No hazardous constituents more difficult to incinerate than
dioxane using the heat of combustion hierarchy may be
incinerated at Condition 1 defined below
- No hazardous constituents oiore difficult to incinerate than
phenol using the heat of combustion heirarchy may be
incinerated at Condition 2 defined below
The following incinerator operating conditions must be maintained
subject to the previous stipulations:
Condition 1: - The waste feed rate must be no more than 600 Ib/hr
- The minimum allowable combustion zone temperature
is 2150°F measured at (specify location of
temperature sensing device used during the
performance test); at lower temperatures, the
waste feed cut off system must be activated
Condition 2: - The waste feed rate must be no more than 600 Ib/hr
- The minimum allowable combustion zone temperature
is 1950°F measured at (specify location); at
lower temperatures, the waste feed cut off system
must be activated
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Test 1
Test 2
Temperature
°F
Time
30 minutes
FIGURE 5-1
SAMPLES OF CONTINUOUSLY RECORDED TEMPERATURES
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deviation might be overly restrictive. The purpose of allowing variations in
operating conditions is to allow adjustments to maintain steady state
conditions without activating the waste feed cut-off system. The
potential problems of permitting unsteady state operation and confining
operation too strictly may be avoided by allowing variations that are a fixed
percentage of the mean or median temperature. In this example, a 10 percent
variation from the mean temperature was allowed, permitting a minimum operating
temperature of 1950°F. The permit writer should not specify the minimum
operating temperature attained during a performance test as the minimum
permitted temperature. The minimum temperature in this example was 1550°F and
it is highly improbable that the same performance would be obtained at a mean
temperature of 1550°F as at a mean temperature of 2160°F.
Steady state conditions were definitely achieved during Test 2; the
temperature chart does not continually increase or decrease and there are no
temperature spikes. The mean temperature measured at 15-minute intervals is
2350°F. The standard deviation is 45°F and if this value was used to specify
the permit condition, it would be overly restrictive. As in the previous
example, a deviation of approximately 10 percent is allowed, giving a minimum
operating temperature of 2150°F. The records of other continuously monitored
parameters may be evaluated similarly.
5.2 Discussion of Example 2
5.2.1 Case Description
Sample permit application data for the second example are presented
in Table 5-3. The purpose of this example is to illustrate the permitting of
mixed wastes and spiked wastes, and permitting on the basis of total thermal
input. The incinerator in this example is a multiple chamber hearth burning a
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TABLE 5-3
SAMPLE PERMIT APPLICATION DATA - EXAMPLE 2
Incinerator: Multiple Chamber Hearth
Waste Characterization Data
Waste Blend 1 Waste Blend 2
Physical State Solid Liquid
Heating Value 5000 Btu/lb 80,000 Btu/gal
Organically-Bound Chloride 4-6% <0.7%
Content
Ash Content 10-25% 0.5%
POHCs Phthalic anhydride Pyridine
Paraldehyde Toluene diamine
Phenol Aniline
One trial burn was conducted generating the following data:
Incinerator Operating Conditions
Test 1
Waste Feed Rate - Waste 1 200 Ib/hr
Waste 2 15 gal/hr
Combustion Chamber Temp.
Primary 1400-1600°F
Secondary 1750-1900°F
Waste Feed Location - Waste I Primary
Waste 2 Primary
Performance Results
DRE - all POHCs 99.99%
Particulate Emissions 0.072 gr/dscf at 50% excess air
HC1 Emissions >4 Ib/hr
99.2% removal efficiency
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mixture of solid hazardous wastes and a mixture of liquid hazardous wastes.
The waste characterization data in this example are the results from the
analysis of waste mixes comprised of several different hazardous wastes.
Analytical data are provided on the two mixed wastes in the form each enters the
incinerator. The data indicate that all solid wastes received at the facility
are blended so that the heating value is greater than 5000 Btu/lb, the
organically bound chloride content ranges from 4 to 6 percent, and the ash
content is between 10 and 25 percent. Similarly, all non-halogenated liquid
wastes are blended to achieve the stated values.
The POHCs present in the wastes are not considered very difficult to
incinerate if the heat of combustion hierarchy is used. The applicant may
spike these wastes with hazardous constituents more difficult to incinerate
than phthalic anhydride and pyridene, particularly if the incinerator feeds
are blended and such constituents may be present in future shipments of
wastes. If the wastes are spiked, using less incinerable compounds such as
maleic anhydride or nitroaniline, and satisfactory performance is achieved,
the permit could be written to allow the incineration of wastes containing a
greater number of hazardous constituents. Spiking wastes reduces the number
of trial burns that might be necessary if wastes are received containing
hazardous constituents that are more difficult to incinerate than those
specified in the permit.
One trial burn was conducted with both hazardous waste mixes being fed
to the incinerator simultaneously. The range of combustion chamber
temperatures was determined using the method presented in Example 1. The
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trial burn performance results were in compliance with the regulatory
requirements.
5.2.2 Development of Permit Conditions
The permit conditions developed from the trial burn data are presented
in Table 5-4. Because the physical states of the waste mixtures are
different, the permit must specify the compositions of two separate
incinerator feeds. The permit conditions can be written directly from the
waste characterization data and the incinerator operating information because
the results of all the incinerator performance tests comply with the
regulatory requirements. The permitted composition limits of waste blends
are specified in the same manner as wastes from one specific source. The waste
feed rates and other permit conditions may be specified in the units most
conveniently monitored by the applicant.
Waste feed is restricted to the primary chamber. If the wastes were
fed to the secondary chamber, the residence time would be decreased and
satisfactory performance might not be achieved. The permit is written so
that up to 200 Ib/hr of Waste Blend 1 or 15 gal/hr of Waste Blend 2 may be
fed to the primary chamber individually, or these amounts of the wastes may
be incinerated simultaneously. Hazardous wastes containing more readily
incinerated hazardous constituents than phthalic anhydride and pyridene may
be fed in greater amounts, providing that the total thermal input is less
than 2.2 million Btu/hr and the other permit restrictions on waste
composition are satisfied.
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TABLE 5-4
SAMPLE PERMIT CONDITIONS - EXAMPLE 2
• The permittee is allowed to incinerate the following hazardous
wastes:
Waste Blend 1: - The physical state of the hazardous waste must
be solid
- Minimum heating value is 5000 Btu/lb
- Maximum organically bound chloride content is 6%
- Maximum ash content is 25%
- No hazardous constituent more difficult to
incinerate than phthalic anhydride may be
present in the waste
Waste Blend 2: - The physical state of the waste must be a liquid
- Minimum heating value is 80,000 Btu/gal
- Maximum organically bound chloride content is 0.7%
- Maximum ash content is 0.5%
- No hazardous constituent more difficult to incin-
erate than pyridine may be present in the waste
• Waste Blends 1 and 2 may be incinerated together only if the following
conditions are maintained:
- The maximum feed rate of Waste Blend 1 is 200 Ib/hr to the
primary chamber at (specify location)
- The maximum feed rate of Waste Blend 2 is 15 gal/hr to the
primary chamber at (specify location)
- The maximum thermal input to the incinerator is
2.2 million Btu/hr
- The minimum combustion zone temperature in the primary chamber
is 1400°F measured at (specify location)
- The minimum combustion zone temperature in the secondary
chamber is 1750°F measured at (specify location)
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5.3 Discussion of Example 3
5.3.1 Case Description
The third example of developing permit conditions is a more complex
variation of the second example, illustrating the correlation of incinerator
operating conditions with waste composition in a permit. The sample
application information is summarized in Table 5-5. The incinerator is a
multiple chamber hearth unit burning solid waste and non-halogenated liquid
waste mixtures as in the second example. A mixture of halogenated liquid
wastes is also incinerated at different operating conditions and non-
halogenated waste is fed to the afterburner to maintain high temperatures.
Two trial burns were conducted. The first trial burn was the same as
the trial burn conducted in Example 2, where only the solid waste and the
non-halogenated waste blends were incinerated. During the second trial burn,
all three waste blends were fed to the primary chamber of the incinerator and
»
the non-halogenated waste mixture was fed to the secondary chamber. Higher
combustion zone temperatures were maintained during the second trial burn
than during the first trial burn in order to ensure adequate destruction of
the chlorinated materials. The results of both trial burns were in
compliance with the regulatory performance standards.
5.3.2 Development of Permit Conditions
The permit conditions developed from the trial burn data are summarized
in Table 5-6. The permit is similar to the one developed in Example 2 but
includes additional operating requirements for the incineration of the
halogenated waste blend.
One of the operating requirements is the restriction on waste feed
location. Wastes may only be fed to the incinerator at the locations used during
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TABLE 5-5
SAMPLE PERMIT APPLICATION DATA - EXAMPLE 3
Incinerator: Multiple Chamber Hearth Equipped with Liquid Injection
Waste Characterization Data
Physical State
Heating Value
Organically-Bound
Waste Blend 1
Solid
5000 Btu/lb
4-6%
Waste Blend 2
Liquid
80,000 Btu/gal
<0.7%
Waste Blend 3
Liquid
40,000 Btu/gal
15-25%
Chloride Content
Ash Content
POHCs
10-25%
Phthalic
anhydride
Paraldehyde
<0.5%
Pyridene
Toluene
diamine
Aniline
Phenol
Two trial burns were conducted generating the following data:
Incinerator Operating Conditions
<0.5%
Tetrachloroethane
Hexachlorobenzene
Hexachlorobutadiene
Waste Feed Rate - Waste Blend 1
Waste Blend 2
Waste Blend 3
Combustion Chamber Temperature
Primary
Secondary
Waste Feed Location - Waste Blend 1
Waste Blend 2
Waste Blend 3
Test 1
200 Ib/hr
15 gal/hr
0
1400-1600°F
1750-1900°F
Primary
Primary
Test 2
150 Ib/hr
15 gal/hr
10 gal/hr
1400-1600°F
1850-2000°F
Primary
Primary & Secondary
Primary
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TABLE 5-5 (Concluded)
Performance Results
Test 1 Test 2
ORE - all POHCs 99.99% 99.99%
Paniculate Emissions 0.069 gr/dscf 0.076 gr/dscf
HC1 Emissions 4 Ib/hr 4 Ib/hr
>99.4% removal >99.8% removal
efficiency efficiency
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TABLE 5-6
SAMPLE PERMIT CONDITIONS - EXAMPLE 3
• The permittee is allowed to incinerate the following hazardous
wastes:
Waste Blend 1: - The physical state of the hazardous waste must
be solid
- Minimum heating value is 5000 Btu/lb
- Maximum organically bound chloride content is 62
- Maximum ash content is 252
- No hazardous constituent more difficult to
incinerate than phthalic anhydride may be
present in the waste
Waste Blend 2: - The physical state of the waste must be a liquid
- Minimum heating value is 80,000 Btu/gal
- Maximum organically bound chloride content
is 0.72
- Maximum ash content is 0.52
- No hazardous constituent more difficult to
incinerate than pyridine may be present in the
waste
Waste Blend 3: - The physical state of the waste must be a liquid
- Minimum heating value is 40,000 Btu/gal
- Maximum organically bound chloride content
is 252
- Maximum ash content is 0.52
- No hazardous constituent more difficult to
incinerate than tetrachlorethane may be present
in the waste
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TABLE 5-6 (Concluded)
• Waste Blends 1 and 2 may be incinerated only if the following
conditions are maintained:
- The maximum feed rate of Waste Blend 1 is 200 Ib/hr to the
primary chamber at (specify location used during performance
test). Up to 750,000 Btu/hr of wastes containing more easily
incinerated hazardous constituents, and satisfying the other
permit conditions, may be fed at this location.
- The maximum feed rate of Waste Blend 2 is 15 gal/hr to the
primary chamber at (specify location used during performance
test). Up to 1.2 x 10^ Btu/hr of wastes containing more
easily incinerated hazardous constituents, and satisfying the
other permit conditions, may be fed at this location.
- The minimum combustion zone temperature in the primary
chamber is 1400°F measured at (specify location).
- The minimum combustion zone temperature in the secondary
chamber is 1750°F measured at (specify location).
• Waste Blend 3 may be incinerated only if the following conditions
are maintained:
- The maximum feed rate of Waste Blend 1 is 150 Ib/hr to the
primary chamber at (specify location used during performance
test). Up to 750,000 Btu/hr of wastes containing more easily
incinerated hazardous constituents, and satisfying the other
permit conditions, may be fed at this location.
- The maximum feed rate of Waste Blend 2 is 15 gal/hr, no more
than 5 gal/hr of which may be fed to the secondary chamber at
(specify location used during performance test). Up to
1.2 x 10 Btu/hr of wastes containing more easily
incinerated hazardous constituents, and satisfying the other
permit conditions, may be fed at this location.
- The maximum feed rate of Waste Blend 3 is 10 gal/hr to the
primary chamber at (specify location used during performance
test). Up to 400,000 Btu/hr of wastes containing more easily
incinerated hazardous constituents, and satisfying the other
permit conditions, may be fed at this location.
- The minimum combustion zone temperature in the primary
chamber is 1400°F measured at (specify location)
- The minimum combustion zone temperature in the secondary
chamber is 1850°F measured at (specify location)
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"a satisfactory performance test. During Test 2 of this example, 10 gal/hr of
Waste Blend 2 were fed to the primary chamber and 5 gal/hr were fed to the
secondary chamber, or afterburner. Therefore, the permit conditions stipulate
that no more than 5 gal/hr of Waste Blend 2 can be fed to the afterburner at the
same location used during the performance test and Waste Blend 3 cannot be fed
to the afterburner. If Waste Blend 3 was fed to the afterburner, the residence
time in the incinerator would be less than if it was fed to the primary chamber,
and a 99.99 percent ORE might not be attained. In the absence of performance
data, it must be assumed that a 99.99 percent ORE will not be achieved and the
permit is developed accordingly. Up to 15 gal/hr of Waste Blend 2 may be fed to
the primary chamber because the residence time is increased if the waste is fed
to the primary chamber instead of the afterburner. The increase in residence
time will increase the ORE, and such operation is permitted.
Because of the restrictions on waste feed locations, the permit cannot be
written on the basis of total thermal input to the incinerator. Maximum thermal
inputs may be specified at each feed location, but unless significant amounts of
auxiliary fuel were used during the performance test, the allowable feed rates
of easily incinerated wastes will not be much greater than the feed rates used
for the performance test. Table 5-6 demonstrates how the thermal input at each
feed location may be specified in a permit.
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6.0 REFERENCES
1. U.S. Environmental Protection Agency, Industrial Environmental Research
Laboratory, Cincinnati, Ohio. Engineering Handbook for Hazardous Waste
Incineration, SW-889, September 1981.
2. American Society for Testing and Materials, Philadelphia, Pennsylvania.
Standards for Analysis, 1980.
3. Arthur D. Little, Inc., Cambridge, MA. Sampling and Analysis Methods
for Hazardous Waste Combustion, First Edition, Prepared for U.S.
EPA/IERL-RTP, February 1983.
4. Kiang, Y. Total Hazardous Waste Disposal Through Combustion, Industrial
Heating, December 1977.
5. North American Manufacturing Company, Cleveland, Ohio. North American
Combustion Handbook, Second Edition, 1978
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